|Date:||November 27, 1998|
|TO:||State Directors of Vocational-Technical Education|
State Directors of Community, Technical and Junior Colleges
State Tech-Prep Coordinators
|FROM:||Patricia W. McNeil|
Assistant Secretary for Vocational and Adult Education
|SUBJECT:||Guidance for FY 1999 State Plan Requirements|
This memorandum provides guidance regarding options for the submission of State plans due April 2, 1999, to apply for funds that become available July 1, 1999, under the Carl D. Perkins Vocational and Technical Education Act (Perkins III). The guidance, provided in this memorandum, covers Title I (Assistance to States), as well as Title II (Tech-Prep Education).
Prior to the passage of new legislation, the Division of Vocational-Technical Education conducted three workshops focusing on three key themes: education reform, accountability, and academic and occupational standards. Personnel from the vocational education, school-to-work, and JTPA communities attended these workshops. Our intent was to provide States with a foundation for preparing State plans.
Now that we have new legislation (PL 105-332), we are offering several options for States to choose from in meeting the requirements to submit a State plan for Perkins III by April 2, 1999. Due to the requirements of the Cash Management Improvement Act (CMIA), the date on which the State may begin to obligate funds under the Perkins Act may be delayed if the State does not submit a plan under one of the options described below by the deadline. An untimely submission may jeopardize a State's July 1, 1999, receipt of funds under the Perkins Act.
Regardless of which option the State chooses, we expect that States may build on successful practices and strategies already in place under Perkins II to meet the requirements of Perkins III. For example, States that have well established and successful vocational and academic integration programs may use this framework to ensure learning in the core academic and vocational and technical subjects and provide students with a strong experience in, and understanding of, all aspects of an industry, as required in Perkins III [section 122(c)(5)].
In addition, State plans must meet the requirements to remove barriers to equity in Section 427(b) of the General Education Provision Act (GEPA), as well as include assurances required by Perkins III and the Education Department General Administrative Regulations (EDGAR) forms (enclosed). State plans must also include a budget request.
We are offering several options for States to choose from in submitting State plans by April 2, 1999. These options include a transitional plan, a multi-year plan, a unified plan, or a consolidated plan. We recommend that the application for Tech-Prep funds be submitted as part of the State plan regardless of the option the State chooses. These options reflect conversations we had with many of you and with other groups. Therefore, we are providing the following guidance and attachments to facilitate the timely submission of State plans.
I. Transitional Plan (three options)
Section 4 of Perkins III authorizes the Secretary to take steps to provide for the orderly transition from the Carl D. Perkins Vocational and Applied Technology Education Act (Perkins II) to Perkins III. There are three options under the transitional plan that a State can choose from depending on its readiness to implement Perkins III. By April 2, 1999, a State could file a one-year transitional plan covering the period July 1, 1999, through September 30, 2000, whether or not it plans eventually to file a multi-year plan as part of a State Unified Plan covering vocational education under Section 501 of Workforce Investment Act of 1998 (WIA), or a multi-year plan under Section 122(d) of Perkins III for the period July 1, 2000, and beyond.
Although the three transitional plans need not contain the depth of discussion expected in a full five-year plan, options 1 and 2 must include the levels of performance and be sufficiently rigorous for the State and this Department to reach agreement on the levels of performance for the period July 1, 1999, through September 30, 2000, for each of the core indicators of performance identified in Section 113(b)(2). Option 3 provides a different method of addressing the performance requirements.
Under the first option, the one-year transitional plan for FY 1999 funding should contain a general description in response to all items identified as "plan content" in Section 122(c) of Perkins III. Emphasis should be placed on the following key areas:
- activities designed to meet or exceed the State adjusted levels of performance --
- activities to provide comprehensive professional development for personnel --
- involvement of parents, teachers, local businesses and labor organizations in programs --
- allocation of funds to all eligible recipients --
- activities for individuals who are members of special populations --
- data reporting on students= participation --
- relation of programs to occupational opportunities --
- methods for joint planning and coordination with other Federal programs --
- promotion of nontraditional training and employment preparation --
- submission of complete, accurate and reliable data --
The second option for the one-year transitional plan is for those States that cannot meet the April 2, 1999, submission date because the State cannot fully satisfy the requirements in State and federal law by that date. We would expect those States to submit a letter of assurance addressing three areas: 1) goals or objectives that the State hopes to achieve, 2) process and timelines for developing the transitional plan in order to comply with the various requirements of the State plan including all of the public requirements, and 3) fiscal accountability including the amount of funds to be used to carry out State-level activities, and the process use to distribute program funds within the State. The letter of assurance also should include a completed assurances sheet and certification page, including the signature of the authorized State representative. After the completion of the state planning process, the State then would submit its transitional plan addressing the items included in I. A (Option 1) to this Department by May 15, 1999. As stated before, CMIA deadlines apply, however, we will try our best to work with you to meet your needs by releasing the federal funds by July 1, 1999.
The third option for the one-year transitional plan is for States to extend their current Perkins II plan with revisions or amendments. As stated at the regional workshops, amendments may or may not be substantial. The State decides in the first instance whether the change is substantial, however, the final decision will be made in the course of reviewing the State plan amendments. In order to qualify under this option, the State must clearly delineate the reasons why it cannot apply under the other available options. If a State selects this option, we expect that the State will describe how it will rapidly move towards implementation of Perkins III and how it will address the following requirements: 1) process and timelines for meeting Perkins III programmatic accountability provisions; 2) rationale for amendments or revisions identifying current needs and how the State is planning to meet these needs; 3) collaborative efforts with other Federal programs and stakeholders; and 4) fiscal accountability.
During the first year of approved transitional plans, States should continue their planning process in order to submit a final, comprehensive plan that promotes student achievement and career preparation. Approval of this final plan would be the basis on which funds would be awarded for FY 2000 and beyond.
II. Five-Year State Plan
A State choosing this option must ensure that the plan includes all of the required elements of Perkins III in detail. As indicated earlier, new State plans must meet the requirements of Section 427(b) of GEPA, as well as include the assurances required by Perkins III and EDGAR.
III. Unified Plan
Section 501 of WIA encourages States to develop a unified plan for, at least, two or more of the following programs: 1) workforce investment activities under Title I of WIA; 2) adult education and literacy under Title II of WIA; 3) secondary vocational education (if the State legislature approves); and 4) postsecondary vocational education. This plan must include all of the elements required for a separate 5-year plan. If a State does not include both secondary and postsecondary vocational education in its unified plan, it must submit a separate vocational education plan for that part which is not included.
IV. Consolidated Plan
Section 14302 of the Elementary and Secondary Education Act (ESEA), as reauthorized by Title I of the Improving America's Schools Act (IASA), allows State education agencies (SEA) to apply for federal program funds including Perkins III funds through a single, simplified consolidated plan rather than through separate funding applications or plans. The approval of a consolidated plan does not alter the obligation of an SEA and its grantees to continue to comply with all programmatic requirements of each program. An SEA may consolidate administrative funds under specified programs. In addition, approval of a consolidated State plan does not authorize commingling of program funds.
Again, the State will be expected to include the levels of performance and be sufficiently rigorous for the State and this Department to reach agreement on levels of performance for the period July 1, 1999, through September 30, 2000, for each of the core indicators of performance identified in Section 113(b)(2).
If your State is interested in this option, please contact the Division of Vocational-Technical Education for further information.
Section 203(c) of Perkins III requires States to submit to the Secretary an application in the manner and accompanied by the information that the Secretary may require to receive Tech-Prep Education funds. We recommend that the State's Tech-Prep application be submitted as part of the State plan. We also recommend that the Tech-Prep application follow the same specific procedures and requirements for whichever option your State chooses for the State plan.
As mentioned before, we are offering the same options for Tech-Prep as for the Basic Grants. Therefore, we are providing additional guidance for the three options under transitional Tech-Prep applications.
I. Transitional Plan (three options)
Under the first option, the one-year Tech-Prep transitional application must contain a general description of any changes the State intends to make to the existing State Tech-Prep plan in order to respond to changes in Perkins III's Tech Prep Education Act, Title II.
For instance, will the State make the awards on a competitive basis or on the basis of a formula?
How will the State review applications based on their potential to create an effective Tech-Prep education program? Are applications addressing the seven elements of Section 204(c)? For example,
- How will the curriculum be changed to help program participants meet academic standards developed by the State?
- Will the program design be modified to include work-based or worksite learning?
- Will the program design be modified to use educational technology and distance learning?
What will the State do to give special consideration to applications that address the five elements of Section 205(d)? For example:
- providing education and training in areas of significant workforce shortages?
- demonstrating how the program will help students meet high academic and employability competencies?
How will the State ensure that applicants address the special rule in Section 204(a)(2) regarding expanded membership in Tech-Prep consortia?
How will the State collect data to address the reporting requirements in Section 206?
The second option for the one-year transitional Tech-Prep application is the same as for the Basic Grants. The State may submit a letter of assurance addressing the three areas indicated in I. B(Option 2). The application would then have to be completed and submitted to this Department by May 15, 1999.
The third option would extend the Perkins II Tech Prep application but address Perkins III requirements as follows: 1) any changes the State intends to make to the existing State Tech Prep application in order to respond to changes in Perkins III's Tech Prep Education Act, Title II; 2)process and timelines for meeting Perkins III accountability provisions including addressing the reporting requirements in Section 206; and 3) fiscal accountability including the amount of funds to be used to carry out Tech Prep activities, and the process use to distribute Tech Prep funds to consortia within the State. Again, the State will clearly delineate the reasons why it cannot meet other available options and how it will rapidly move to implement Perkins III.
II. Five-Year State Plan
A State choosing this option must ensure that the Tech-Prep application includes all of the required elements of Perkins III in detail (section II.under Basic Grants).
For the other two options -- Unified Plan and Consolidated Plan- the Tech-Prep application will follow the same specific procedures and requirements.
In Title II, Tech-Prep Education, a new initiative referred to as high schools at community colleges, is included (Section 207). When funds are appropriated for this demonstration program, additional guidance will be provided to the States.
Please feel free to contact Ron Castaldi of my staff at (202) 205-9441, or use the electronic mailbox at OVAE@ed.gov, or view our web site at http://www.ed.gov/offices/OVAE/CTE/legis.html for any assistance you may need.