Avenues to Successfully Recruit Host Agencies


Transcript by
Federal News Service
Washington, D.C.

GARY GONZALEZ:  All right.  Well, we’re going to move on.  And right now, I want to turn things over to our speaker – our moderator, Judith Gilbert, from SCSEP’s at the national office – from SCSEP at the national office.  Take it away, Judith. 

JUDITH GILBERT:  Thanks so much.  And welcome to all of you.  We wanted to do that poll right up front because we were really concerned with wanting to be sure that these webinars – the subject area was going to be of use to you.  And while we’ve been hearing from a number of you that recruitment may not be a – participants may not be a problem right now, we thought that it would be important to get your feedback on that.  So thank you very much for responding to that.  And thank you again for being here and being able to log in, in spite of some minor little technical glitches. 

Our main presenter today is someone that is familiar to almost all of you, if not all of you, and that is Joyce Welsh from AgeWise Solutions.  Joyce has been the primary trainer for the SCESP program and has done training with you and for you and for us for many years now and Joyce is going to be – I’m going to turn it over to Joyce to walk us through this really important issue about recruiting host agencies for SCESP.  Joyce?

JOYCE WELSH:  Okay.  Thank you, Judith.  And greetings to everyone out there in cyberspace who joined us.  We’re delighted.

As Judith may have mentioned earlier, over the past number of months we have been observing growing participant waiting lists in programs around the country and inquiries coming into project offices at an increasing pace.  So what we were thinking might have been a real crisis in finding eligible applicants may not be as critical an issue as we thought maybe in many places.  But the point being programs will have increasing difficulty bringing new participants on board if they don’t have sufficient host agencies to assign them to.  After all, an applicant does not become a participant until they have been assessed and assigned to a host agency.

So the questions we will be focusing on this afternoon are really twofold.  First, are you satisfied with the host agencies you do have?  And second, do you have enough to be able to rapidly place the additional participants that you will be provided with stemming from the stimulus money which will very soon become available to you?  So we figured it was chicken and the egg, cart before the horse, any way you look at it we decided that talking about how to recruit and sign up host agencies was the number one issue to position you to be able to be very responsive to the stimulus dollars.

So the first question:  Do you have enough?  And this really is a pretty simple computation.  At the very least you should have a number equal to your slot level.  Ideally – and increasingly more and more grantees are telling us – between 10 and 20 percent over your modified slot level is really ideal.  So again, that’s a simple computation.  Take your modified slot level and multiply it times – let’s split the difference and say 115 percent and you will get the ideal number of host agencies that you should have in your bag of tricks.

The second question, or the second point you really need to be thinking about, is taking a really hard look at the host agencies you have.  And you need to really be pretty brutal about this and figure out if they are the same host agencies you have had forever and ever, year after year, some of you decade after decade.  They may not have – these old-timers may not have been keeping pace with the program changes as it has evolved over the years and indeed over the decades.  So you really need to brutally assess whether they are indeed true partners providing good quality training to your participants and support as they work through their individual employment plan.  Or indeed are they just a place to house your participants, thinking that they either own a slot or have jobs to be filled?  And regretfully I know they are still out there.

So if yours is like most programs out there, recruiting new host agencies will expand your options and opportunities for both meeting your goals and successfully managing the stimulus money you will soon receive. 

Host agencies are one of the three critical partners that we have on this program:  participants, employers and host agencies.  Host agencies are in a very real sense the core of our program as truly participants spend up to 90 to 95 percent of their time on the program and a host agency site.  So the integral role that they do play is providing participant development and eventual achievement of IEP.  They should enhance and develop participant skills and work habits.  It is really, really important that all host agencies understand that they do not own slots and they do not have positions to be filled.  If they haven’t been keeping pace with the program over the last number of years, now is indeed the time to reeducate them.

Participant placement in host agencies should not be a given.  You should develop a variety of sites so you’ll have multiple training opportunities and will be able to support a lot of different assessed needs.  You should have more sites than participants, a) to reduce your dependency on any one particular host agency and b) to really give you options for rotating participants as they progress through their IEP.  You need to set high expectations, expect good job training, expect support for their IEP; and if you’re not getting it you really need to discontinue using host agencies that do not meet those expectations.  There is no other way we’re going to meet our goals in a truly damaged economy if we are not constantly reaching out and bringing new host agencies into the fold and, two, making sure that all the host agencies we have are indeed playing the role that they should. 

Okay.  When reaching out to new host agencies you really do need to make a concerted effort to find agencies that fill at least one of these four roles that you see on the screen very, very well.  I would suggest even making a grid for yourself and placing each of your host agencies into one of those quadrants as where they have their greatest strength because you really should make an attempt to recruit and nurture host agencies in each one that have each one of these particular strengths.  That will give you the greatest option in working with participants, no matter what the barriers are personally that they bring to the program or what their skill level happens to be. 

You need to consciously look for those host agencies that offer very good training, and we mean training; not working, but training in jobs and skills that are in demand in the community.  These really are extremely valuable as host agencies and you should make a very tough assessment of what you’ve got and make a concerted effort to reach out and bring more with the ability to train into your fold. 

The second bullet, assisting with job search through local contacts, this is a very valuable host agency to nurture and to place participants in as they are becoming more job ready.  These are the host agencies that have high standing in the community, name recognition, perhaps their (board share ?) is very well respected.  And just being able to have that agency’s name on a resume or a letter of recommendation signed by this person might be exactly what a participant need to have their application bubble up to the top and let them get an interview. 

The third type, providing a supportive environment, is – it’s really critical to have quite a variety of host agencies in this category.  And that’s where you will initially place participants that come to you with multiple barriers.  Before they can begin learning an occupational skill, it’s really important to overcome some of those personal barriers first so they are free to learn and develop.  It’s also good to have these supportive environments in place as individual participants perhaps age in place on our program.  With the new durational limits we perhaps will not be having quite as many individuals 75-plus as we have now.  But there is a need as individuals do age in place to perhaps be rotated into a more supportive environment. 

Lastly, but certainly not least, are host agencies that have the ability to hire.  And those still exist.  And certainly in economically troubled times it is really important to have enough agencies like this as part of your partnership because that will be the quickest way to place our individuals on the program.

So again, I would urge you to make some kind of a grid and really do a hard analysis of the agencies you do have now, placing them for their primary strength in one of these quadrants.  And then actively recruiting to beef up any quadrant that seem to be lacking in any host agency areas.

There’s another way you can slice and dice your host agencies to get the biggest bang for the buck and that is perhaps ranking your host agencies based on their ability to either support participants, train them, provide advanced training or hire.  This could be another grid with the first level being just basic skill/work experience, sort of correlating to the supportive environment host agency.  Another level could be the intermediate who do provide training but perhaps not in the more technologically oriented skills.  Those of course would be the “more advanced,” quote/unquote, host agencies.  And that – as you are actively recruiting new host agencies, you might want to keep that in mind as well that you really will be assessing their capacity to train your participants over time.

So now that you know what you are looking for, the second question is how are you going to find them?  Host agencies must be 501(c)(3) organizations or public agencies.  Okay.  That’s not 501(c)(4)s or (c)(6)s or anything else.  They must be 501(c)(3)s or public agencies.  These three sites will pretty much give you what you need to know based on where you are; they have different levels of thoroughness. 

The first one,, will – you would go to that URL.  About halfway down the page there is an icon that says “federal resources” and then “non-profit organizations.” And all you need to do is type in zip code and every single 501(c)(3), from a one-person office to a major organization, will pop up.  You need to be very judicious as you go through this list because, again, it is everybody that has a 501(c)(3).  You would want to click on each organization and you’ll get a profile.  That profile will tell you the size of the organization in terms of how many staff do they have?  How big is their budget?  What is their vision?  Needless to say, you want to make sure that supervision will be adequate, so there’s sufficient staff on hand; and that the mission would give you a broad avenue for designing training opportunities for your positions.  So is the first URL to go to for 501(c)(3)s. 

The second URL,, et cetera, also will give you 501(c)(3)s.  All you need to do is type in your city and state and you’ll get a complete listing.  There is also an addendum to this that’s right up there on that Web site and that provides a listing of organizations whose names were unable to be included in the latest online version. 

So between those first two you should be able to pretty much gather the universe of 501(c)(3)s.  What I don’t want you to do is forget public agencies because they are a very good source of training and even hiring – well, when budgets don’t have them frozen – of your participants. 

So that last URL,, is where you will go to find your public agencies.  And there is a place to click on the lower right hand side and you’ll put whatever level of government is appropriate to you and your location.  You can find federal agencies, state, local, and even tribal agencies.  And what they will do is give you a complete list by city, by county, or by town.  So no matter whether you are urban or rural you should be able to use this Web site for public agencies and the first two for the private non-profits. 

So now that you know who and where these potential host agencies are you need to design an efficient and effective way of reaching them.  You need to identify your agency and program, of course, and invite them to join you as a partner.  Most grantees use the process of designing a letter essentially introducing who and what you are and what your goals are, and then enclosing an application blank that will capture enough information that you can make at least an determination whether that particular organization would be a good partner. 

You then would follow up either by telephone to get more information.  Most grantees then call a general orientation meeting if you’re doing a wholesale recruitment and have a lot of interested agencies that want time.  And at that time, review pertinent information, sign agreements; but again, before you are ready to assign someone you really are going to want to do an on-site visit both to do a safety check and to make sure you have enough information about that organization and their staff and their budget so you will be able to make pretty good decisions regarding potential maintenance of effort problems. 

I would put a parenthesis now and tell you at the end of this webinar we will be spending a goodly amount of time on the maintenance of effort question. 

Okay.  Further, with regard to recruiting host agencies, you do not want to be the best kept secret in town.  You really need to be out of your offices and making contact and really embarking on public information, activities and efforts.  You should be branding your program as an important community partner.  Feature stories to local newspapers help sanction your products and services and support your outreach efforts.  So before that letter and application blank hits the mail, the week before you should really consider trying to get a story placed in the local newspaper talking about your program, who you are and what you do.  Then when the letter hits it will resonate and individuals will know what it’s about and be more likely to respond. 

Secondly, you should be building connections with key people and organizations with the potential to bring attention and credibility to your program.  Many of your host agencies have human service newsletters that go to both potential participants as well as individuals and organizations that are potentially really good partners.  And don’t forget other staff at your agency.  Everyone sits on boards, committees and taskforces, and recruit them to recommend organizations to be partners.  And of course your best host agencies are also partners for giving you good referrals.

Making your pitch so you attract real partners and not agencies that only see free labor, it’s important that you really talk to them – to your best host agencies now.  Find out what they value.  Find out what benefits you provide.  And then you can also ask them what they were hesitant about.  What barriers about your program tend to exist?  Because your letter, your pitch, has to frame the benefits you provide and also deal with any hesitations they may have before they even know they have them. 

So before we leave this one piece I just want to say one quick word about faith-based organizations.  They certainly make excellent partners, especially in this economic climate because they often are the agencies that provide food and clothing and services to folks who are really in need.  So you need to be reaching out to faith-based groups, however there are two caveats.  Any service that your participant is providing to their training must be open and available to anyone in the community, not just the specific denomination or faith.  And two, there can be no prayer or worship when and where the participant is in training.  But other than those two caveats, they do make excellent organizations.

Okay.  Finally, we’re going to take a look at maintenance of effort.  The economic and budget cuts will make you – I promise you – the most popular program in town, if indeed it hasn’t happened already.  But forewarned is forearmed.  You are not a source of free labor to compensate for budget reductions, reductions in force or furloughs.  SCSEP assignments must expand existing services or create a new service.  It is very important that both you and your host agencies understand that your participants are there to supplement the staffing that exists, not supplant the staffing that exists. 

So there are two really important issues to keep in mind with regard to maintenance of effort.  First, you need to make sure your staff knows what to look for when monitoring current host agencies and entering into agreements with new ones.  That’s really critical.  If you don’t know what a violation of maintenance of effort is you are really vulnerable hanging out there.  Secondly, I want you to make sure that participants know to contact you if their training assignments suddenly change, if they get additional tasks or if they suddenly find themselves, quote, “helping the cause” by undertaking tasks performed by former employees. 

This last point is something to really keep your eye on as many participants really, truly identify with their host agency – sometimes more than with you – and they can easily fall into that, quote, “just helping out” syndrome, especially if everyone else at the agency is pitching in and undertaking additional tasks.  It’s times like this when the economy is tanking and budgets are being cut that you really have to have your radar super sharpened because maintenance – potential violation of maintenance of effort really rises to the front. 

The law is very clear.  Participant assignments must be in addition to budgeted employment and should not – and should result in an increase in services provided by that agency.  Okay.  So the community service assignment itself it’s easy to apply the litmus test once you make the match.  Is the service that the participant will be providing based on their training the same as other employees are providing?  Or, if so, they have to expand that service; they have to be doing something in addition to what budgeted staff are already providing.

On the other hand, the downturn in our economy has definitely impacted on the capacity of many organizations to provide services to people who are really in desperate need.  They’ve lost jobs.  They’ve lost their homes.  And you really should consider helping those agencies that have greatly increased demand for their services but no way to increase their staff to meet growing needs.  And that’s organizations like food pantries, like shelters.  Even the One-Stop programs and systems that we are partners with, they really would value the partnership with SCSEP to help them meet this growing demand. 

Okay.  The maintenance of effort clause in our statute states that SCSEP must not reduce the number of employment opportunities available to participants, one; and two, must not impair existing contracts or substitute federal funds for other funds.  Now, this first point, the first bullet, what that really means in plain English is that participants cannot perform core agency functions.  The question you need to ask yourself as you’re reviewing potential or current host agencies is would the agency hire someone to perform the function if SCSEP – that the participant is performing if the program disappeared tomorrow?  You need to remember that our participants are in training.  They’re learning and honing skills; they are not doing a job.  So you need to be careful how your training descriptions read and you must fit that training description within the context of the overall agency staffing pattern and services provided.  That’s the litmus test. 

So what is okay is extending hours of services open and available, for example.  Perhaps increasing the number of clients that they reach and serve.  Perhaps assisting with opening a branch or a satellite of that facility or service.  All of those things are okay.  What is not okay is things such as providing participants to human service programs that have received budget increases over the years but they never seem to budget for staff because they know they can fill those positions for free with our participants.  What is not okay is having participants serve as key administrative staff or, as we see occasionally, opening or closing an agency or satellite office.  Yes, that satellite office may be expanding a service; remember, our participants are in training.  They need supervision, guidance and direction and they do not belong by themselves sitting out in the community somewhere. 

The second bullet, “must not impair existing contracts,” that refers to any office services that are contracted out, such as maintenance or janitorial services, using – sometimes ADP functions or data entry are contracted out.  Host agencies cannot terminate those contracts, saving that money and using our participants to perform that same function.  Okay. 

And then the final two maintenance of effort conditions that host agencies must abide by are, first, assignments must not result in displacement of currently employed workers.  That includes partial displacement such as reduction in hours on non-overtime work, reduction in wages or employment benefits.  We received recently an example of this – or a potential example of this – when employees – part time employees of a home health agency were let go and the project received a request for participants, purportedly to learn the skills in this growth industry but in reality to replace those part time workers that they had let go.  And this clearly is a violation of maintenance of effort. 

Be careful as well, especially if you use public agencies as host agencies, for furloughed workers or workers with reduced hours, as this is a – is happening more and more at public agencies around the country.

The final bullet to be aware of is that our participants must not perform the same or substantially the same work which was performed by a person on layoff.  And this is pretty straightforward.  The governing words, though, are “the same or substantially the same.” So if the accountant got laid off you could put a participant there in another function, just not in training to be a payroll person or an accountant. 

You need to be really aware of what’s going on in your communities with the host agencies that you have and have recruited because budget and revenue cuts probes non-profits to look to SCSEP to keep their services flowing and doors open.  Support positions especially fall into this category.  Even though good training might be provided and good work experience developed, you still need to be sure that they are not replacing folks who have been laid off.

In bad economic times agencies tend to trim what we call the low-lying fruit first, those lower skilled jobs with tasks that can be redistributed amongst surviving staff or, as they will try, by a SCSEP participant.  You need to be very vigilant against this happening.  Be alert to changing conditions at current host agencies and carefully gather appropriate data on newly recruited ones.  And that means data on their budget, their staffing pattern and the services that they provide.

Okay.  In general that’s where we are in terms of recruiting host agencies.  But Judith is going to make a few final comments especially focusing on the maintenance of effort issue. 

MS. GILBERT:  Thanks, Joyce.  We know that this is a very difficult issue for all of you, especially in these times.  And so that’s one of the main reasons why we wanted to do this webinar today to raise these issues because it is very clearly in our statute.  And so what you need to do to make sure that you’re doing things correctly, we have some suggestions. 

First of all, you really do need to understand the law.  While we have gone over each of the four elements in the law, I want to remind you of exactly where you can find that language.  It’s actually on the second page; easy to find.  But it’s in section 502, little b, 1g.  And those four elements that Joyce listed on the previous two slides are exactly there in those – you just pay attention to the exact words. 

You’re going to need to use your best common sense as you try to determine whether or not something is a maintenance of effort violation.  There are going to inevitably be gray areas.  While we’ve given you some examples of things that are okay – they’re on one side of the scale – and things that are not okay on the other, my guess is that many of the things that will come up will be somewhere a little bit like one and a little bit like the other.  You’re going to just have to, as I say, use some judgment.  Pay attention clearly to those words.  I think the layoff one is one that comes up the most often and the statute is clear that it says “the same or substantially the same” job.  I think we might have had a sense that, oh, if an organization has had layoffs then we can’t put anybody there because that would be maintenance of effort violation.  It may very well not be a maintenance of effort violation if it’s not the same or substantially the same job. 

Also there’s a question about the period of time and we’re going to have to get back to you on exactly what that is.  It can’t be last week or last month but it doesn’t have to be five years ago either that the person was laid off.  So we’re trying to come up with a reasonable answer, some guidelines that you can go by.  And for the moment you should think about it as more likely to be years – one or two – rather than months, one or two.  Right? 

So actually Louisa Reynolds (sp) from our legal office is here with us and she just passed me a note and this is information that may be very good news for you, that 90 days – as long as it’s more – that 90 days is the time.

LOUISA REYNOLDS:  Well, what I wanted to put in is that perhaps a comparable situation is with the H1B visas – in the Department of Labor regulations regarding for H1B visas provides 90 days.  However, that’s a different program so there isn’t anything concrete right now with SCSEP and that’s perhaps a policy matter we should discuss.  But you could consider that some sort of guidance there but I wouldn’t say that that’s concrete that 90 days is 90 days.  You could use that as some sort of guidance but there might be situations where that would not be applicable in the SCSEP program. 

But I wouldn’t say it has to be – I would say certainly use your common sense.  A year is probably sufficient time.  What I’ve seen recently in legal – not just in the visa situation – the H1B visa – but also – I believe the stimulus act also referred favorably to this 90 days for the H1B visa.  But again, that was just for the H1B visa.  But because it’s a Department of Labor regulation I give it some weight.  That’s all I could probably say is I’d give it some weight.

MS. GILBERT:  That’s helpful.


MS. GILBERT:  We’re being our usual – for the most part you can rely on this as being firm, but not – anyway.  The point is please don’t play fast and loose with this and let – and have people going in and filling positions that – because of layoffs.  It is a sad situation that host agencies are in.  There’s no question about the pain that 501(c)(3)s are suffering at this point.  But we do want you to read the law, understand it, use common sense. 

And when you have a question – and this is the best advice that we can give you – is when you’ve got a situation, document the reasoning and the rationale for your decision.  And I would say this is the decision that something is not a maintenance of effort violation, therefore it is okay for you to place a participant.  Just document that and keep that on file because obviously if maintenance of effort violations are found after the fact there’s the potential that you could have disallowed costs.  And we don’t want anybody to suffer that unnecessarily. 

And if an answer about maintenance of effort is not an obvious one and it’s – then you really need to be consulting with your federal project officer.  But make sure that you’ve thought this through and look at the law and understand the law and know that neither we nor anyone else is going to be able to answer definitively 850 different individual – (inaudible) – situations.  It’s going to require judgment on your part. 

So we hope that we have not sufficiently confused you with something that we hope that we were going to give you some guidance on recruiting host agencies, because you are going to need many more host agencies as you get the stimulus funds very, very soon. 

There was a question – we’re going to turn to questions now.  There was a question very early on with Joyce’s numbers.  And she was talking about host agencies but really it’s host agency slots because there in fact are going to be host agencies where you’re going to be able to place more than one person, or larger organizations that have different divisions. 

MS. WELSH:  That’s true, though I would caution you not to use the word “slot” because we’re trying to program our host agencies into not feeling ownership.  Words have power.  But I think Judith’s point is really well taken.  A large private non-profit hospital would have a dozen different divisions and opportunities for training and that’s really what we’re talking about:  opportunities for training in different skill areas.  And you should have at least that number of opportunities as you have modified slots, and ideally 10 to 20 percent more. 

MS. GILBERT:  Yes.  Because ideally you’re going to choose a host agency that is appropriate for the participant.  That’s the first criteria and so you need to have choices so that you can – because all participants don’t come in looking like just the host agencies that you happen to have. 

MS. WELSH:  Okay.  We have a question.  And Judith and I are sitting right next to each other so maybe we’ll take a crack at each of them.  And the question really is, how do we prevent host agencies from moving to a “this is my slot/my position” mentality?  Because it is hard, according to this individual, not to see SCSEP as a free employee.  And you’re right; it is difficult.  The only thing you can do is keep educating, educating, educating.  Use the annual renewal of that host agency agreement, for example, as more than just whiting out the date and resigning it and the same old thing.  Use this as an opportunity to really evaluate the partnership and go through each point on that host agency agreement.  And if the host agency really isn’t providing training as it relates to the IEP, then you’ve got to say we’re rotating this, this and this.  Usually you just have to rotate somebody once or twice and not replace that position to get – for folks to get the message.

MS. GILBERT:  I think that this kind of attitude of “this is my position and this is my free employee” is really in many ways the way it used to be in a lot of places.  And I think we’ve tried very hard over the last decade or so to help host agencies understand that, but I would have to admit not always successfully.  So –

MS. WELSH:  Another reason to have more host agencies than you do participants –

MS. GILBERT:  Right. 

MS. WELSH:  – because you just have to bite the bullet and rotate sometimes.  Easier said than done if you are in a small town or rural area and don’t have a lot of options.  I truly do understand that and that just means you have to work with them personally, one-on-one, as often as it takes until they understand. 

MS. GILBERT:  And at the same time it is another argument for going on to (sic) – .com – and finding out – I think people that have done that have found out that there are in fact a whole lot more 501(c)(3)s than they ever knew existed in their geographic area.  Or 

MS. WELSH:  Yeah.  Try those Web sites and see what you can come up with.  Bottom line is the more competitive you can make your participants or housing one of your – training one of your participants – the better quality you’re going to get from every host agency.  It’s a lot of work but it’s really worth the time. 

There are a few questions a long the lines of length of time at host agencies and, “How long would you allow an agency to take advantage of our participant’s help, for example?”  And that really is based on your particular grantee’s policies.  There is nothing in the statute that has a time limit on how long you can be in a host agency.  The department recommends that you rotate based on the individual employment plan.  And if that individual has learned all they can at that host agency then it’s time to rotate them to another one. 

With that said, those of you who know me speaking out of the other side of my mouth, I will say first consult your grantee because each grantee has their own policies and procedures and one of them usually is how long an individual can stay in a host agency.

MS. GILBERT:  And in fact we do know that there are host agencies that are not in the position and are not ever going to be in the position of hiring but that they are very, very good training sites for participants.  And so whether or not you use a host agency shouldn’t be based just on the fact of whether or not they can hire.  It’s just one of the considerations. 

MS. WELSH:  Another question is with regard to the One-Stop career centers as host agencies and a concern that they are in the midst of layoffs, which I’m not aware of but perhaps in your community that’s true. 

MS. GILBERT:  I think that’s unlikely.

MS. WELSH:  Yeah.  I mean, we’re really kind of surprised at that question but I’m trying not to editorialize the question. 

MS. GILBERT:  Well, but I think there are lots of layoffs in communities but they’re not at the One-Stop centers.  And so we’re talking about the One-Stop being a host agency and this is expanding services –

MS. WELSH:  That’s right.

MS. GILBERT:  – that would not have ordinarily been available.

MS. WELSH:  Yeah.  I may have talked too quickly through that slide.  But the point I was trying to make is they are getting increasing demand for their services by growing numbers of clients and they don’t have additional staff.  So we could really be a very good partner with them and expand their ability to serve a growing population. 

MS. GILBERT:  A couple questions around host agencies and the numbers.  One person has asked, “How many participants should be at a host agency that has many divisions or departments?”  And the answer is there is not any rule of thumb about that.  And in fact if you’ve got an agency that has a lot of divisions, why, you’ve got probably lots of opportunities. 

But as the flipside of that, there is a question about multiple grantees using the same host agency.  There is no absolute prohibition about more than one grantee using a host agency.  However, we have had a strong recommendation that you not do that except – certainly the One-Stops are a clear exception to that. 

MS. WELSH:  Rural areas, especially.  The department is very sensitive to the fact that you don’t have quite the variety or number. 

MS. GILBERT:  The reason for the preference – the very strong preference – against having more than one grantee using the same host agency is because grantees have different policies about things and it is confusing to participants.  And so if participants are our primary concern, as they must be, then that seems to us as though that is the wisest, most prudent course to take. 

MS. WELSH:  There is a question asking the most effective way to handle a maintenance of effort violation at a host agency.  And certainly I think we need – you live in your communities.  You’ve got to have a good working relationship with all your partners.  So there’s not to be public pillory in the town square.  I would certainly assume that they were unaware of this condition that is part of our statute and sit down and meet with them and walk through in simple English what the law intends that our participants may do and may not do.  And give them the opportunity to undo the maintenance of effort violation, meaning move the participant into another training area at that same host agency, which you would then of course monitor closely over the next period of time.  But I would always assume that individuals really didn’t understand the maintenance of effort issue before I would shred up their host agency agreement. 

MS. GILBERT:  And it would seem prudent as you’re signing up host agencies – and even reviewing them – to make clear to them what the maintenance of effort rules are so that they know upfront and maybe even sign something when they sign your agreement.  It should have language in there that says I will not commit any maintenance of effort violations so that they’re – at least they’re on notice as to what the rules are.

There is a question about is there any potential for waivers for some of these host agency restrictions with the stimulus money, because WIA is allowing waiver requests even though they may or may not be granted.  Our understanding at this point is that SCSEP language in our statute, we have no waiver authority.  But the question has been raised and I certainly will raise it but I think that it’s extremely unlikely because we have to have authority to do it.  And WIA does have waiver authority and SCSEP does not.  Sorry about that.  Great idea, though.

MS. WELSH:  Okay.  There’s one final – this is a comment, and I think a really good comment, and that is that a review of in-demand occupations could also be used to help you consider what host agencies might be good matches to the IEP.  That’s another really good resource that was not mentioned, so thank you whoever shouted that one into the room. 

There are indeed many other questions that are out there, as well as comments.  And what I’d like to do is assure you that posted onto this site will be the Q&A and answers to questions we haven’t had the time to get to.  I know the hour has passed and a lot of folks are probably dropping off so –

MS. GILBERT:  The other – a couple of other alternatives if your specific question wasn’t answered is to consult with your federal project officer.  Also, as you know, we do have regular all-grantee conference calls and we have one next Wednesday.  And when we open it up for questions I know all of you well enough to know that you’re not shy about asking – the more difficult the questions are I think the better people like it.  Not me, but we certainly are open to that. 

And quite frankly – I’m being really serious now – we do want to be able to provide you with as much guidance as we possibly can about what is really a very, very difficult area, especially given the fact that we’re going to have stimulus money and at the same time the economy is such that the maintenance of effort violations would be more likely to emerge in any case. 

So with that I would like to turn it – say thank you very much for your participation and turn it back to Gary. 

MR. GONZALEZ:  Thanks, Judith.  Well, thanks for sticking with us if you did.  Don’t want to take too much of your time up.  I just wanted to speak to you very, very briefly about Workforce3One.  As you know, it’s a tool built for you and by you – and we’re going to be getting the site back up hopefully by the end of today so you can have access not only to the PowerPoint – but the recording and transcript will be up in the next two business days. 

So I’m actually going to walk you through how you’re able to access those resources.  I’m going to bring up actually the file share window that you can download the PowerPoint in in just a second.  But to access these resources on Workforce3One, you’ll click the Resources link to the top left of the home page.  You’ll be taken to the Site Search page.  From there, you can click the Site Search – I’m sorry – Search Type category and click the “webinar recordings” option.  You can also type in today’s title as a keyword or just do a date search as well.  And it’ll be the transcript and the recording that’ll be up in two business days.  The PowerPoint, I’m going to be putting up on your screens in just a second so that you can download it. 

And I’m going to bring that up right now, so if you just bear with me.  You’ll be seeing that option – the file share window at the bottom of your page.  And to download that PowerPoint, you’ll just mouse over, left click the title of the PowerPoint, and click the “save to my computer” option at the bottom of that file share window.  A new Web browser’s going to pop up and then you’ll be able to save the PowerPoint to anywhere on your hard drive. 

Again, just a little bit about Workforce3One.  As you know, it’s a tool built for you and by you.  You can use it to find engaging communities of practice where you can share your ideas and information and more with others.  You can also join live Web conferencing events that feature leaders and experts from industry and from government, such as today’s.  It’s also a means of registering to be informed of news and events as they occur.  So we really encourage you to make note of Workforce3One, as it’s a powerful tool funded by ETA and powered by you, the community. 

If you can also learn more about the workforce investment system, you can do so by visiting or by calling 1-877-US2-JOBS. 

All right.  With that, I want to conclude today’s session by thanking everyone for their time, and again, apologizing for the inconvenience with Workforce3One being down.  But it looks like we got the bulk of you able to attend today’s session.  So again, thanks for bearing with us.  Also, I want to thank today’s speakers for joining us as well, Judith, Joyce, for joining us.  I think I’m forgetting someone in the room.  I’m sorry. 

MS. REYNOLDS:  Louisa. 

MR. GONZALEZ:  Louisa, I’m sorry – Louisa for taking the time out of their day as well. 

So we hope to see you on future webinars.  Have a good day, everyone.