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DCLPublicationDate: 5/1/97 DCLID: CB-97-5 AwardYear: Summary: Information regarding the Job Location and Development Program under the Federal Work-Study programs. May 1997 CB-97-5 SUMMARY: Information regarding the Job Location and Development Program under the Federal Work-Study programs. REFERENCE: This letter supplements Chapter 7, Section 6 of the Federal Student Financial Aid Handbook. Dear Colleague: The enclosure to this letter provides additional information in the form of Questions and Answers on the Job Location and Development (JLD) Program. The JLD Program along with the Federal Work-Study (FWS) Program and the Work-Colleges Program are known collectively as the Federal Work-Study programs. With the funding for the FWS Program for the 1997-98 award year increasing to $830 million, many institutions have expressed an interest in the JLD Program. The JLD Program offers an excellent opportunity for institutions to locate and develop off-campus jobs for currently enrolled students who are FWS and non-FWS eligible. The Department strongly encourages institutions to use the JLD Program to expand community service job opportunities for students, particularly as reading tutors of children. We appreciate your assistance and cooperation as we work to expand the Federal Work-Study programs. If you have any questions on the JLD Program, please contact the Department's SFA Customer Support Branch. Staff members are available Monday through Friday between the hours of 9:00 am and 5:00 pm (Eastern Time) at 1-800-433-7327. You may e-mail an inquiry to the Customer Support Branch at csb@ed.gov or fax an inquiry at (202) 260-4199. Sincerely, Elizabeth M. Hicks Deputy Assistant Secretary Student Financial Assistance Programs Enclosure Job Location and Development Program 1. QUESTION: What is the Job Location and Development (JLD) Program? ANSWER: The JLD Program is one of the Federal Work-Study programs. An institution is allowed to use part of the Federal funds it receives under the Federal Work-Study (FWS) Program to establish or expand a JLD Program to locate and develop off-campus jobs for currently enrolled students who want jobs, regardless of their financial need. The JLD Program encourages students to participate in community service activities. 2. QUESTION: What is the specific dollar limit on the FWS Federal funds that may be used for the JLD Program? ANSWER: An institution may use up to the lesser of $50,000 or 10 percent of its total FWS allocation to establish or expand a JLD Program. 3. QUESTION: Does the JLD Program require institutions to provide an institutional share? ANSWER: Yes. When an institution participates in the JLD Program, the Federal funds may pay up to 80 percent of the allowable costs. The institution must provide the remaining 20 percent of allowable costs either in cash or in services. The institution's 20 percent share may be either (1) 20 percent of each allowable cost, or (2) varying percentages of allowable costs as long as its total expenditures of institutional funds and/or provision of services equals at least 20 percent of the total allowable costs for the JLD Program. The institution must maintain records that indicate the amount and sources of its share. The fiscal procedures and records requirements for JLD are the same as those for the FWS Program. 4. QUESTION: Does the JLD Program provide for a waiver of the institutional share requirement? ANSWER: No. The JLD institutional share requirement, unlike the institutional share requirement for FWS earnings, cannot be waived. 5. QUESTION: What are allowable costs of carrying out the JLD Program? ANSWER: Allowable costs of carrying out the JLD Program include: - staff wages and salaries (may also include fringe benefits if they are the same as those paid to other institutional employees in comparable positions and the fringe benefits are not paid to an FWS student); - travel expenses; - printing and mailing costs; - telephone charges, including installation of a separate line for off-campus employers; - costs for supplies, equipment, and furniture; - newspaper or other types of advertising; and - costs for workshops for students and employers. 6. QUESTION: What costs are not allowable under the JLD Program? ANSWER: Costs that are not allowable are costs related to purchasing, constructing, or altering the facilities that house a JLD project. Indirect administrative costs also are not allowable. One example of an indirect administrative cost is a portion of the salary of someone who is not directly involved in the program such as the JLD director's supervisor. Other examples of indirect administrative costs are lighting, heating, or custodial costs incurred as a part of the normal operations of the facility in which the JLD Program is administered such as the financial aid or placement offices. 7. QUESTION: If an institution is eligible to participate in the FWS Program, is it automatically qualified for JLD? ANSWER: Yes. An institution eligible to participate in the FWS Program is also eligible to participate in the JLD Program. 8. QUESTION: When an institution that is currently participating in the FWS Program wants to participate in the JLD Program must it make prior contact with the Department or have its Program Participation Agreement (PPA) revised? ANSWER: No. An institution that is currently participating in the FWS Program does not have to contact the Department for the purpose of participating in the JLD Program. The fact that the institution has an executed PPA for the FWS Program means that the institution is also able to participate in the JLD Program without any prior contact with the Department or revision to its PPA. The institution under the PPA agrees to administer the JLD Program according to the appropriate statutory and regulatory provisions. 9. QUESTION: Is there any information that an institution must provide to the Department if it participates in the JLD Program? ANSWER: Yes. An institution that participates in the JLD Program during an award year must provide information about its JLD activities on the Fiscal Operations Report and Application to Participate (FISAP). The institution provides total JLD expenditures, Federal expenditures for JLD, institutional expenditures for JLD, number of students for whom jobs were located or developed, and total earnings for those students. 10. QUESTION: Must an institution under the JLD Program generate a certain amount of student wages? ANSWER: Yes. Under the JLD Program, an institution must locate and develop jobs that generate total student wages exceeding the total amount of the Federal funds spent under the JLD Program. 11. QUESTION: May an institution participating in FWS enter into a written agreement with other participating institutions to establish and operate a JLD Program? ANSWER: Yes. An institution that is participating in FWS may enter into a written agreement with other FWS participating institutions to establish and to operate a JLD Program for its students. The agreement must designate the administrator of the program and must specify the terms, conditions, and performance standards of the program. Each institution that is part of the agreement retains responsibility for properly disbursing and accounting for the Federal funds it contributes under the agreement. For example, each institution must show that its own students have earned wages that exceed the amount of Federal funds the institution contributed to locate and develop those jobs. 12. QUESTION: What types of organizations should an institution contact to locate and develop jobs through the JLD Program? ANSWER: Jobs located or developed under the JLD Program may be for either a profit or nonprofit employer. 13. QUESTION: May the JLD Program be used to locate and develop jobs for FWS students? ANSWER: Yes. Federal JLD funds are to be used to pay the institution's costs of establishing and administering the JLD Program under which jobs are located and developed for FWS and non-FWS eligible students. However, using JLD funds to find jobs only for FWS students would not satisfy the statutory requirement to expand off-campus jobs for currently enrolled students who want jobs, regardless of their financial need. 14. QUESTION: May JLD Program funds be used to locate and develop jobs at the institution or at other eligible institutions? ANSWER: No. The institution cannot use JLD funds to locate and develop jobs at the institution or at other eligible institutions. The JLD funds can only be used to locate and develop jobs off- campus. 15. QUESTION: May JLD funds be used to pay students whose jobs were located and developed through the program? ANSWER: No. The JLD funds are not to be used to pay students whose jobs were located and developed through the JLD Program. 16. QUESTION: May an institution employ FWS and non-FWS students as staff in the JLD Program? ANSWER: Yes. An institution may employ FWS and non-FWS students as staff in the JLD Program. The prohibition against using JLD funds to locate and develop jobs at any institution does not include the hiring of students to work as staff for the JLD Program itself because the JLD staff jobs were not located and developed with JLD Program funds. 17. QUESTION: May the Federal JLD funds be used to pay the non-Federal share of the wages earned by FWS students working as staff in the JLD Program? ANSWER: No. The use of any funds allocated under the FWS Program is prohibited from being used to pay the non-Federal share of FWS compensation to its students. However, since JLD allowable costs include staff salaries, the institution with its own funds would pay the non-Federal share of the wages earned by FWS students working as staff in the JLD Program and count those funds in meeting the minimum 20 percent institutional share requirement. 18. QUESTION: May the institution under the JLD Program locate and develop jobs for students to obtain upon graduation? ANSWER: No. The program locates and develops off-campus employment opportunities for students during and between periods of attendance. The program may not be used for the placement of students in jobs upon graduation. 19. QUESTION: Does the JLD Program encourage locating and developing jobs for students that provide community services? ANSWER: Yes. The statement of purpose for the JLD Program includes the encouragement of participation in community service activities. Further, the JLD Program description notes that funds are to be expended to establish or expand a program to locate and develop jobs, including community service jobs. However, the JLD Program does not have a specific minimum community service requirement as does the FWS Program. 20. QUESTION: Does the JLD Program have a requirement similar to the one for the FWS Program that jobs, to the maximum extent practicable, complement and reinforce the educational programs or vocational goals of the students in question? ANSWER: Yes. Under the JLD Program, the jobs located and developed must be suitable to the scheduling and other needs of the students and, to the maximum extent practicable, must complement and reinforce the educational programs or vocational goals of these students. 21. QUESTION: May the jobs located and developed under the JLD Program be full-time? ANSWER: Yes. The jobs located and developed under the JLD Program may be either full-time or part-time. 22. QUESTION: May jobs located and developed under the JLD Program result in the displacement of employed workers? ANSWER: No. The jobs located and developed under the JLD Program must not displace employees or impair existing service contracts.

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