NCBA On-The-Job Experience (OJE) Supplementary Proposal

NCBA On-The-Job Experience (OJE) Supplementary Proposal In order to implement an OJE component within its SCSEP project, a grantee must provide a separate proposal delineating the provisions of its OJE program. This supplement contains the VDA OJE proposal, provisions, and a contract format as required by Older Worker Bulletin No. 04-04 dated April 12, 2004. OJE Narrative In order to shift away from a reliance on host agencies for placement of SCSEP participants, VDA has developed criteria for an OJE program that conforms to the specification of Older Worker Bulletin No. 04-04. VDA expects to utilize the OJE framework for both new participants and for participants who have been in the program at the end of PY 2005. In all cases, participants will have completed a minimum of two weeks of community service with a host agency before being placed under an OJE contract with a private or public (non-host agency) employer. VDA sees great potential for the OJE component as a means of encouraging employers to use older workers and see the benefits derived from employing this population group. The reimbursement features of OJE will be used along the same lines as On-The-Job training in mainline DOL funded programs – to compensate employers for the costs of developing skills needed to perform a job. OJE will not be used simply as a subsidy to hire participants. OJE will be limited to one opportunity per year (twelve month period) for any given participant. Any one employer will be limited to no more than five participants in the same job category within a twelve month period. Copies of the OJE agreements with employers will be maintained in the participant file folder and available for inspection by appropriate monitors. If requested, information on the OJE contract will be provided to DOL. All OJE participants in VDA’s DOL-funded subprojects will be enrolled in SCSEP through the normal screening process which includes review of all relevant eligibility criteria. Since the same screening process will apply, only eligible applicants will be enrolled in the program and thus only eligible participants will be considered for OJE – the OJE population will come from the SCSEP eligible participant population. Employer Reimbursement/Participant Wages VDA’s subprojects expect to use both the model of reimbursement for employers and the model of paying OJE participants wages during the OJE experience. The decision will be made at the subgrantee or subproject level. VDA anticipates that the majority of its subprojects will use the reimbursement model. The reimbursement model allows the participant to be in an actual employer-employee relationship during the experience and puts a greater level of commitment on the employer since the participant is actually on the employer’s payroll, with the subproject reimbursing the employer for skill development costs. VDA will keep open the option of using either a 100% reimbursement for up to four weeks of OJE or up to 50% reimbursement not to exceed twelve weeks. VDA will use these as upper limits and subprojects will negotiate with each employer on duration and amount of reimbursement, based on the participant skill level and the requirements of the job. In no case will an OJE exceed twelve weeks in duration. Typical OJE Participant and Employer VDA’s fifteen (11) statewide subprojects are quite diverse. It would be impossible to predict what the exact specification of each OJE would be prior to using this new approach. However, VDA can project what the typical experience will look like and will provide this to subproject coordinators as guidelines. VDA will allow subproject coordinators to use their discretion in developing OJEs staying within the limits established for the program. VDA envisions that OJE will be most appropriate for those participants: - Who fall within the 55 to 70 age range, - Who have some work experience, - Whose IEPs indicate fairly minor skills gaps that can be filled in a short time with an employer, - Who is looking for part-time work, - Who has demonstrated skill competency through a host agency assignment for a minimum of two weeks but more typically much longer - Who is mobile enough to accept the OJE assignment without disrupting commuting arrangements and - Who is deemed to be most likely to benefit from the experience and to be a fit with a non-host agency employer. VDA envisions that OJE will be used primarily with small businesses in the retail, healthcare, personal service, and social service sectors, whose training programs and systems are less structured than those in large employers but who have nonetheless demonstrated through interviews that they are committed to hiring OJE participants and can see mutual benefit in participating in the project. The general characteristics of these employers will include: - Demonstrated, through interview, a commitment to hiring older workers - A willingness to develop an informal training program geared to the needs of the OJE participant - A commitment to recordkeeping on the OJE skills attainment in line with the contract provisions - A commitment to hire the participant at the start of the OJE - Demonstrated adherence to all applicable safety and health requirements of the state and local jurisdiction and no recent history of violations (through self-attestation by the employer) - A commitment of continuing to employ the participant after the OJE reimbursement period is completed - A commitment to meeting recordkeeping requirements and to allow follow- up with the placed participant after the OJE is completed. A training plan will be incorporated into each contract with an employer. The training plan will outline the skills to be developed and the methods of developing those skills. Training plans will be individualized based on the participant’s needs as reflected in the Individual Employability Plan. The specific content will be tailored to individual participant needs and employer expectations. The training plan will be kept relatively simple but will provide sufficient detail to ensure skill attainment is tracked. No existing host agencies will be considered as OJE sites. Safety and Health Work Conditions As noted in the selection criteria for employers to participate in the OJE project, safety and health considerations will be part of the employer screening process. OJE participants will be monitored on the same basis as regular SCSEP participants. Subproject staff routinely include health and safety issues in their on-site reviews. The selection process will be the primary means of ensuring that only employers with good safety and health records are selected for participation. Since the participants will be in unsubsidized jobs after the OJE, monitoring would not be appropriate but VDA’s subprojects will ensure former participants have an open door to raise issues about safety and health issues and may be considered for re-enrollment if they report unsafe or unhealthy conditions. Such reports would be crucial factors in considering employers for future OJE contracts. Community Service Since one of the major purposes of the SCSEP is to provide valuable community service, all participants will be placed in a community service assignment at a host agency for a minimum of two weeks before being placed in an OJE. VDA envisions that the time in a community service assignment will typically be much longer than two weeks in order to develop the participant work skills and to assess the readiness for an OJE. Subproject staff will monitor participant progress and make selections for OJE participation based on suitability and readiness. Recordkeeping OJE records will be maintained in the same manner as records for regular participants. Each participant will have a folder in which pertinent documents relating to his/her application, eligibility determination, assessment results (initial and updates), IEP (initial and updates), host agency assignment, OJE contract, OJE training plan, and progress reports through monitoring will be kept. All other necessary documentation will also be kept in the participant folder. Participant folders are reviewed during on-site monitoring visits from VDA. Types of OJE Projects As noted, VDA anticipates OJE primarily with small employers, typically in the retail, healthcare, personal services, or social services fields. This will not exclude other appropriate employers being used but gives a sample of the kinds of activities engaged in. Typically VDA envisions customer service positions as the primary OJE placements. Therefore it is anticipated that the training involved for OJEs will typically include customer service training as well as employer specific system acclimation, e.g. using selected computer software utilized by that employer or, if less automated, acclimation to forms and practices of the employer. As a rule, VDA envisions entry level positions as the primary placement for OJE. Since this program option is intended to be available in fifteen (15) diverse areas of the state, no definitive criteria are being set on wage levels except that VDA expects that higher than minimum wage positions will be used in the OJE with a general expectation that placement wages will average $8.00 or more. OJEs are expected to pay the prevailing wage for the position to which a participant is assigned. OJE positions are projected to be approximately 20 hours per week. Some might be higher, given individual circumstances, but none will be lower. The length of the OJE will average six weeks but each situation will be driven by individual participant and employer needs. Subprojects will negotiate with the employer on what the duration and level of reimbursement will be, taking into account the community service performance standards and the needs of the participant and the employer. This is expected to be a highly individualized program option. There will be no upper limit on wages or hours (beyond the 40 hour work week). Worker’s Compensation Since the reimbursement model calls for the participant to be hired by the employer at the start of the OJE, the participant will be covered by the employer’s workers compensation policy as would any other employee. Under the participant wage model, workers compensation will be covered by the SCSEP subproject just as it would be for any SCSEP participant. . Sample Contract A sample OJE training reimbursement contract, OJE letter of agreement, and OJE training plan are included as attachments to this proposal. These are generic documents to be used by subproject coordinators to negotiate with OJE employers. The framework covers all the required items but the detail of what will go into each will result from the assessment of the participant and employer needs.