AwardYear: 1998-1999 EnterChapterNo: 7 EnterChapterTitle: Federal Work-Study Program SectionNumber: 4 SectionTitle: Types of Employment PageNumbers: 19-34 Federal Work-Study (FWS) jobs may be on or off campus. Off- campus jobs must be in the public interest if the work is for a federal, state, or local public agency, or for a private nonprofit organization. However, a school may use part of its FWS allocation to provide jobs in private, for-profit organizations. All FWS jobs must, to the maximum extent practicable, complement and reinforce the student recipient's educational program or vocational goals. COMMUNITY SERVICE JOBS ------------------------- [[Community service requirement--34 CFR 675.18(g)]] Schools are required to make students aware of community service opportunities by encouraging them to get involved in community service activities. Schools are also required to utilize money from their FWS Program for that purpose. There is no restriction as to whether these jobs must be on or off campus. A university or college is not considered a community for the purposes of the FWS Program community service requirements. Also, private, for-profit organizations do not qualify as employers for community service under the FWS Program. In determining whether the service is a community service, the school must always consider whether the service provided by the FWS student primarily benefits the community as opposed to the agency or school. Additional information on the community service component of the FWS Program is available in Dear Colleague Letter CB-94-4, dated March 1994 and in Dear Colleague Letter CB- 97-12, dated July 1997. A school must use at least 5% of its FWS allocation to employ students in community service jobs unless the U.S. Department of Education grants the school a waiver. The Department will approve a waiver only if the school requests one in writing and if the Department determines that the school has demonstrated that enforcing the requirement would cause hardship for students at the school. According to the participation agreement (discussed in the introduction to Chapter 5) between a school and the Department, a school must - allow employment under FWS to be used to assist programs providing supportive services to students with disabilities; - inform all eligible students of the opportunity to perform community services; and - consult with local nonprofit, governmental, and community-based organizations to identify community service opportunities. [[Definition of community services--34 CFR 675.2(b)]] Community services are defined as services that are identified by an institution of higher education through formal or informal consultation with local nonprofit, governmental, and community- based organizations, as designed to improve the quality of life for community residents, particularly low-income individuals, or to solve particular problems related to their needs. These services include - such fields as health care, child care, literacy training, education (including tutorial services), welfare, social services, transportation, housing and neighborhood improvement, public safety, crime prevention and control, recreation, rural development, and community improvement; - work in service opportunities or youth corps as defined in Section 101 of the National and Community Service Act of 1990, and service in the agencies, institutions and activities designated in Section 124(a) of that act;1 - support for students (other than for an institution's own students) with disabilities; and [[Serving as a mentor]] - activities in which an FWS student serves as a mentor for such purposes as - tutoring (discussed on pages 7-23 to 7-26), - supporting educational and recreational activities, and - counseling, including career counseling. 1 At the end of this section are definitions of the terms "service opportunity" and "youth corps program" (as defined in section 101 of the National and Community Service Act of 1990) and a list of agencies, institutions, and activities included in section 124(a) of that act. [[Direct vs. indirect services]] To be considered employed in a community service job for FWS purposes, an FWS student does not have to provide a "direct" service. The student must provide services that are designed to improve the quality of life for community residents or to solve particular problems related to those residents' needs. A school may use its discretion to determine what jobs provide indirect or direct service to the community. The Department does not intend to indicate that certain activities are more important than others or that only jobs that have direct contact with community members are acceptable. For example, an FWS student working for a "meals on wheels" program may prepare meals for the program without having any direct contact with the community residents, yet the service he or she is providing is very important in meeting community needs. [[Jobs that should take priority]] In contacting potential community service agencies, schools should place a priority on jobs that will meet the human, educational, environmental, and public safety needs of low-income individuals. The Department has determined that at this time there is no need to burden schools with a formal definition of low-income individual for purposes of providing community service under the FWS Program. There is no statutory requirement that a particular number or proportion of the individuals must be low-income persons. Some examples of jobs that provide services to persons in the community who may not necessarily be low-income individuals are jobs that provide supportive services to students with disabilities or that prevent or control crime. [[On-campus community service jobs]] On-campus jobs can meet the definition of community services, provided that the services are open and accessible to the community and that they meet the regulatory and statutory provisions pertaining to the applicable FWS Program employment limitations and conditions. For example, it would be acceptable for an institution to set up services on the campus (e.g., tutoring centers or daycare centers) that are open to the community. If the institution sets up sites in the community and opens the services for the community, jobs at these sites would be acceptable. A service is considered open to the community if the service is publicized to the community and members of the community use the service. ESTABLISHING FWS COMMUNITY SERVICE JOBS -------------------------------------------- In developing FWS community service jobs, a school might begin by - determining which types of jobs meet the community services definition, - determining if any of its current on-campus jobs meet the community services definition, - determining if any of its current jobs with off-campus agencies meet the community services definition, and - locating other potential employers. [[Placing FWS recipients]] To place FWS recipients in community service jobs, a school might begin by - determining which FWS recipients would be interested in community service jobs (evaluating the FWS recipients by looking at their degree or certificate programs, interests, and skills) and - determining the number of community service jobs it needs to locate. [[Promoting community service jobs through public relations]] To promote FWS community service jobs through public relations activities, a school might begin by - devising a plan to market community services under the FWS Program to eligible student employers and the community, - obtaining a listing of potential community service agencies, - asking to be a presenter at various organizations' meetings, - engaging in networking activities, - holding and attending job fairs, - hosting a financial aid office "open house," and - visiting local agencies. A school may also get help in developing FWS community service jobs through communication with colleagues at their own school, at other schools, or with other organizations. For example the school may - communicate to the student placement office the community- service requirements under the FWS Program; - talk to colleagues at institutions that participated in the expired Community Service Learning Program to get ideas on implementing, locating, and developing the community service jobs; and - contact local nonprofit, governmental, and community-based organizations to assess their needs and determine what interest exists for employing FWS students. AMERICA READS CHALLENGE -------------------------- Schools are encouraged to place FWS students as reading tutors of preschool-age children and children in elementary school as part of the school's effort to support the America Reads Challenge (refer to Dear Colleague Letter CB-97-12, dated July 1997). This is an important way for schools to meet the community service expenditure requirement under the FWS Program, serve the needs of the community, and give the FWS students a rewarding and enriching experience. Tutoring does not have to be held in a school setting. It could, for example, take place at a public library or community center. The programs that provide this reading tutoring for children may take place during the children's school hours or after school, on weekends, or in the summer. The school may construct its own reading tutor program or become involved with existing community programs. [[100% federal share]] The Department will authorize a 100% federal share of the student's FWS wages if he or she is employed as a reading tutor of preschool- age children and children in elementary school and if the work performed by the student is for the school itself, for a federal, state, or local public agency, or for a private nonprofit organization. (The federal share of FWS wages is discussed in Section 5 of this chapter.) Tutoring may be one-on-one or in a group. Because the Department wants to provide schools with flexibility in determining the job description and duties of a reading tutor, we are not defining "reading tutor" for the FWS Program. An FWS student employed to read to a group of preschoolers in a public library, for example, would meet this requirement. [[Definition of reading tutor]] An FWS student employed as a reading tutor does not have to meet certain statutory or regulatory educational standards or qualifications for the school to receive an institutional-share waiver. However, an FWS reading tutor must have adequate reading skill, and the Department strongly recommends that the tutors be well trained before they tutor. When an FWS student receives training from a reading specialist or expert for sufficient duration and intensity, he or she is more likely to be successful with the child he or she is tutoring. Tutor training should emphasize the importance of the reading tutor's communicating with the regular classroom teacher to maximize effectiveness. Note that because the needs vary from child to child, the amount and type of training for reading tutors will often vary, depending on the child who is being tutored. [[Preschool-age children]] A preschool-age child is a child from infancy to the age at which his or her state provides elementary education. The definition of an elementary school varies from state to state. Because the Department does not wish to interfere with a state's determination of what constitutes children who are in elementary school, we will not provide guidance on the maximum grade level for elementary school for purposes of the institutional-share waiver for tutoring. [[Tutoring in a parochial school]] An FWS student can tutor a child in a parochial school under certain conditions: - The parochial school must be classified as a private, nonprofit school by the Internal Revenue Service (IRS) or a state taxing body - The work may not involve constructing, operating, or maintaining any part of a building used for religious worship or sectarian instruction. - The FWS reading tutor may not use religious material to tutor the child. The Department does not require background checks of FWS reading tutors. However, some state and local jurisdictions may require such checks. The requirements will vary according to the agency or organization involved. [[Using JLD to locate or develop reading tutor jobs]] The Job Location and Development (JLD) Program may be used to locate or develop jobs for FWS students as reading tutors of children. However, using JLD funds to find jobs only for FWS students would not satisfy the JLD statutory requirement to expand off-campus jobs for currently enrolled students who want jobs regardless of their financial need. An FWS reading tutor job might qualify for a waiver of the FWS institutional-share requirement but not qualify as part of the 5% community service requirement. If, for example, a postsecondary school employs FWS students to tutor young children in its daycare center and the only children in the center are those of the school's students, staff, and faculty, the job would qualify for the waiver, but because the daycare center would benefit only the school as opposed to the community, the job would not qualify as part of the 5% community service requirement. [[Using the FISAP to show 100% federal share]] A school is not required to ask the Department for a waiver of the FWS institutional-share requirement to receive the 100% federal share authorization for FWS students employed as reading tutors. Instead, the school should use 100% federal dollars to pay such a student and then show on its Fiscal Operations Report and Application to Participate (FISAP) that it did so. There is no limit on the amount of funds a school can spend from its FWS allocation to pay FWS reading tutors. The Department plans to revise the FISAP to collect data on the number of FWS students employed as reading tutors of children, total earned compensation paid to these students, and the federal dollars spent for the compensation. Training Tutors Under limited circumstances, an FWS tutor can receive FWS wages while he or she is being trained, and these wages can qualify for an institutional-share waiver. This training period must be only for a reasonable and limited length of time. The Department would not consider a training period of an academic term to be reasonable. The Department would consider a reasonable training period to be one that occurs before the student begins tutoring and that does not exceed approximately 20 hours. A school may not pay an FWS student to take an academic course the school developed to provide classroom training on tutoring children to read. An FWS student may take such a course as long as he or she is not paid for taking the course. The wages of an FWS student who is training reading tutors or who is performing administrative tasks related to supporting other people who are actually providing the reading tutoring do not qualify for a federal share of up to 100%; rather, an institutional share is required. A school may use a portion of its administrative cost allowance (ACA) to cover the costs of training an FWS reading tutor. A school may also use a portion of its ACA to cover expenses that are related to employing a student as a reading tutor with a local school district and that the school may not incur with another organization. If, for example, a school district requires all employees to undergo a background check and be fingerprinted at a cost of $40 per employee, the postsecondary school may use a portion of its ACA to cover this cost. The FWS Program does not provide for any additional funds beyond the ACA for technical assistance and training of reading tutors. See Section 5 of this chapter for a discussion of the ACA. Time Spent on Activities Other Than Tutoring The preparation time and evaluation time worked by an FWS reading tutor qualify for an institutional-share waiver as long as the time spent for this purpose is reasonable. For example, the Department would consider attending evaluation and preparation meetings once a week for approximately one hour to be reasonable. The Department wants to give some flexibility because of the value of evaluation and preparation time. However, the goal is to spend funds for FWS students to interact with the children, not for other activities. Remember that it is the FWS reading tutor job, not the student working in the job, that qualifies for the institutional-share waiver. Thus, an FWS student who is working another FWS job in addition to the reading tutor job can be paid with 100% federal funds only for the time he or she is working as a tutor, not for time spent on the other job. If, for example, an FWS student spends only half of his or her time working as a reading tutor (including preparation and evaluation time) and the other half on non-tutoring tasks, the student may be paid 100% federal funds only for half the time and the other half must be paid with a maximum of 75% federal funds and a minimum of 25% nonfederal funds. Documenting the Employment of FWS Reading Tutors A postsecondary school must be able to identify the FWS students who performed tutoring. The school must also be able to provide the job description that demonstrates that these students worked as reading tutors of children, and the school must have records supporting the hours worked and the amount paid to the FWS reading tutors. WORK ON CAMPUS ---------------- A student may be employed on campus at any type of postsecondary institution, including at a proprietary school. An FWS job at any school must, to the maximum extent practical, be related to the student's educational program or vocational goals. [[Work for the school itself or for its contractors]] A school, other than a proprietary school, may employ a student to work for the school itself, including certain services for which the school may contract, such as food service, cleaning, maintenance, and security. Work for the school's contractors is acceptable as long as the contract specifies the number of students to be employed and specifies that the school selects the students and determines their pay rates. A proprietary school also may employ a student to work for the school itself with certain restrictions (discussed below under "Work for Proprietary School, On or Off Campus"). [[Work for a professor]] At any private nonprofit or public school, an FWS student may be assigned to assist a professor if the student is doing work the school would normally support under its own employment program. Having a student serve as a research assistant to a professor is appropriate, as long as the work is in line with the professor's official duties and is considered work for the school itself. However, in a proprietary school, a student may not assist an instructor, as instructional activities are not considered student services. [[Work in a branch campus overseas]] Normally, employment in a foreign country is not permissible under the law. However, a school with a branch campus in a foreign country may employ students under FWS if the branch has its own facilities, administrative staff, and faculty. Students may also be employed by a U.S. government facility such as an embassy or a military base. A student may not be employed for a nonprofit organization in a foreign country. WORK FOR PROPRIETARY SCHOOL ON OR OFF CAMPUS -------------------------------------------------- [[Criteria to work for a proprietary school--34 CFR 675.21(b)]] A proprietary school may employ a student to work for the school itself but only in jobs that meet certain criteria: 1. If the jobs are in community service, they may be either on or off campus. Students employed by a proprietary school and performing community service do not have to furnish student services that are directly related to their education. 2. If the jobs are not in community service, they must be on campus and must - provide student services, - complement the student's educational program or vocational goals to the maximum extent possible, and - not involve soliciting potential students to enroll at the proprietary school. [[Definition of student services--34 CFR 675.2(b)]] The regulations define student services as services that are offered to students and that are directly related to the work-study student's training or education. For example, jobs that provide student services may include, but are not limited to, jobs in a financial aid office or library, peer guidance counseling, and jobs providing social and health services or tutorial services. However, work in the admissions or recruitment area of a school is not acceptable, as this employment could involve soliciting potential students. Maintenance (cleaning dorms) is not acceptable. In general, work that would primarily benefit the school rather than its students is not permissible. For example, a student may not work in the front reception area or in the business office of a school, as those jobs do not provide student services. As stated earlier, a student may not assist an instructor, as instructional activities are not considered student services. WORK OFF CAMPUS FOR NONPROFIT OR GOVERNMENT AGENCY --------------------------------------------------------- [[Work in the public interest]] If a student is employed off campus by a federal, state, or local public agency2 or by a private nonprofit organization, providing jobs related to the student's academic or vocational goals is encouraged, but not required. However, the work performed must be in the public interest. Work in the public interest is defined as work performed for the welfare of the nation or community, rather than work performed for a particular interest or group. 2 Local public agencies include city or county government offices, public schools, community-owned hospitals, public libraries, and community centers. A private nonprofit organization is one in which no part of the net earnings of the agency benefits any private shareholder or individual. An organization must be incorporated as nonprofit under federal or state law. A school classified as a tax-exempt organization by either the federal or state Internal Revenue Service meets this requirement. Examples of private nonprofit organizations generally include hospitals, daycare centers, halfway houses, crisis centers, and summer camps. Nonprofit agencies do not qualify automatically as community service employers for purposes of the FWS Program because the work performed must meet the definition of community services in the regulations. A list of programs or activities that are recognized as appropriate work in community services under the FWS Program is included at the end of this section. In addition, work off campus for a nonprofit agency must be in the public interest. [[Work not in the public interest]] Work is not "in the public interest" if - it primarily benefits the members of an organization that has membership limits, such as a credit union, a fraternal or religious order, or a cooperative; - it involves any partisan or nonpartisan political activity or is associated with a faction in an election for public or party office; - it is for an elected official unless the official is responsible for the regular administration of federal, state, or local government; - it is work as a political aide for any elected official; - a student's political support or party affiliation is taken into account in hiring him or her; or - it involves lobbying on the federal, state, or local level. However, in deciding whether work is in the public interest, schools must consider the nature of the work as well as that of the organization. For example, a student may be employed by a private nonprofit civic club if the student's work is for the club's community drive to aid handicapped children. If the student's work is confined to the internal interests of the club, such as a campaign for membership, the work would benefit a particular group and would not be in the public interest. As another example, a student may work for a private nonprofit membership organization, such as a golf club or swimming pool, if the general public may use the organization's facilities on the same basis as its members. If only members may use the facilities, FWS employment is not in the public interest. [[Political activity--partisan or nonpartisan]] Political activity, whether partisan or nonpartisan, does not qualify as work in the public interest. For example, a student is not considered to be working in the public interest if working at voting polls--even if he or she only checks off the names of those who came to vote and does not pass out flyers supporting a particular candidate. Also, a student is not considered to be working in the public interest if working to support an independent candidate. Another example of nonpartisan political activity is work for a city that is sponsoring political debates. [[Political aide]] Working for an elected official as a political aide also does not qualify as work in the public interest. For example, a student could not represent a member of Congress on a committee. However, a student could be assigned to the staff of a standing committee of a legislative body or could work on a special committee, as long as the student would be selected on a nonpartisan basis and the work performed would be nonpartisan. Under certain circumstances, work for an elected official responsible for the regular administration of federal, state, or local government may be considered to be in the public interest. "Regular administration" means the official is directly responsible for administering a particular function. Such a person would not create, abolish, or fund any programs but would run them. Working for a sheriff would be acceptable, as would working for an elected judge (because he or she has direct responsibility for the judicial system). As stated above, any political activity would not be acceptable-- raising funds for the official's reelection, for example. An FWS position that involves lobbying at the federal, state, or local level is not work in the public interest. [[Work for the Department]] FWS students are prohibited from working for the Department due to the potential appearance of conflict of interest. WORK OFF CAMPUS FOR PRIVATE FOR-PROFIT COMPANIES ------------------------------------------------------- [[Jobs must be academically relevant]] Schools also may enter into agreements with private for-profit companies to provide off-campus jobs for students; however, these jobs must be academically relevant to the student's program of study. (A student studying for a business administration degree could work in a bank handling customer transactions, for example.) Private for- profit organizations do not qualify as employers for community service under the FWS Program. A school may use up to 25% of its FWS allocation and reallocation for an award year to pay the wages of FWS students employed by private for-profit organizations, but the organizations may not hire FWS employees to replace regular employees. [[For-profit organization pays 50% of wages]] The federal share of FWS wages for students employed by private for-profit organizations is limited to 50%. The for-profit organization must contribute the remaining 50%, plus employer taxes (such as FICA, unemployment, and Workers' Compensation). OFF-CAMPUS AGREEMENTS ------------------------ When a school enters into a written agreement--a contract--with any off-campus agency or company that employs FWS students, the school must make sure the organization is a reliable agency with professional direction and staff and that the work to be performed is adequately supervised and consistent with the purpose of the FWS Program. (See the Appendix at the end of this chapter for a model off-campus agreement. The sample need not be followed exactly but serves as a guide.) The agreement sets forth the FWS work conditions and establishes whether the school or the agency/company will be the employer for such purposes as hiring and firing, or paying the nonfederal share of the student's wages or the student's Social Security or Workers' Compensation benefits. The employer is generally considered to be the organization that will control the work of the FWS students-- supervising them at the work site, regulating their hours of work, and generally ensuring that they perform their duties properly. However, the school is ultimately responsible for making sure that payment for work performed is properly documented and that each student's work is properly supervised. [[Liability for on-the-job injuries]] The agreement must also state which organization--the school or off- campus employer--is liable for any on-the-job injuries to the student. The employer is not automatically liable. Federal FWS funds cannot be used to pay an injured student's hospital expenses. [[Payroll responsibility]] The agreement should also define whether the agency/company will assume payroll responsibility and bill the school for the federal share of the students' wages, or whether the school will pay the students and bill the agency/company for its contribution. The school must make up any payments the agency/company does not make. It is the school's responsibility to ensure that FWS payments are properly documented, even if the agency/company does the payroll. To fulfill that responsibility, the school must keep copies of time sheets and payroll vouchers and keep evidence that the students were actually paid (usually copies of the canceled checks or receipts signed by the students). [[Supervising and evaluating off-campus employment]] The school is also responsible for ensuring that each student's work is properly supervised. School officials should periodically visit each organization with which they have an off-campus agreement to determine whether students are doing appropriate work and whether the terms of the agreement are being fulfilled. In determining whether to continue an off-campus agreement, many schools have found it helpful to require that students submit a formal evaluation of their work experience at the end of the assignment. The school may also use the evaluation to help off-campus agencies improve their work programs. Staff members of the off-campus organization must become acquainted with a school's financial aid and student employment programs to better understand the school's educational objectives. The school is responsible for supplying this information. FWS EMPLOYMENT DURING PERIOD OF NONATTENDANCE --------------------------------------------------- A student may be employed under FWS during a period of nonattendance, such as a summer or equivalent vacation period or the full-time work period of a cooperative education program. To be eligible for this employment, a student must be planning to enroll (or to reenroll) for the next regular session. The student's earnings during this period of nonattendance (earnings minus taxes and job-related costs) must be used to pay his or her cost of attendance for the next period of enrollment. [[Documenting student's intent to enroll]] A student whose eligibility for summer FWS employment was based on anticipated enrollment in the subsequent term may fail to register or may decide to attend another school. When a student fails to register for the subsequent term, the school that employed the student must be able to demonstrate that the student was eligible for employment and that the school had reason to believe the student intended to study at that school in the next term. At minimum, the school that employed the student must keep a written record in its files showing that the student had accepted the school's offer of admittance in the upcoming session. [[Study abroad]] A student in an eligible program of study abroad may be employed during the summer preceding the study abroad if he or she will be continuously enrolled in his or her American school while abroad and if the student's study is part of the American school's own program. In such a case, a student may be employed in a qualified position in the United States, at the American school's branch campus in a foreign country, at a U.S. government facility abroad, or in an American company abroad. TERMS USED IN THE DEFINITION OF COMMUNITY SERVICES --------------------------------------------------------- The definition of community services (see page 7-20) includes the terms "service opportunity" and "youth corps program." Section 101 of the National and Community Service Act of 1990 defines the terms as follows: - Service opportunity. A program or project, including a service learning program or project, that enables students or out- of-school youth to perform meaningful and constructive service in agencies, institutions, and situations where the application of human talent and dedication may help to meet human, educational, linguistic, and environmental community needs, especially those relating to poverty. - Youth corps program. A program, such as a conservation corps or youth service program, that offers full-time, productive work (to be financed through stipends) with visible community benefits in a natural resource or human service setting and that gives participants a mix of work experience, basic and life skills, education, training, and support services. LIST OF AGENCIES, INSTITUTIONS, AND ACTIVITIES INCLUDED IN THE DEFINITION OF COMMUNITY SERVICES ----------------------------------------------------------------------- The definition of "community services" includes service in agencies, institutions, and activities that are designated in Section 124(a) of the National and Community Service Act of 1990: 1. Conservation corps programs that focus on - conservation, rehabilitation, and the improvement of wildlife habitat, rangelands, parks, and recreation areas; - urban and rural revitalization, historical and site preservation, and reforestation of both urban and rural areas; - fish culture, wildlife habitat maintenance and improvement, and other fishery assistance; - road and trail maintenance and improvement; - erosion, flood, drought, and storm damage assistance and controls; - stream, lake, waterfront harbor, and port improvement; - wetlands protection and pollution control; - insect, disease, rodent, and fire prevention and control; - the improvement of abandoned railroad beds and rights-of-way; - energy conservation projects, renewable resource enhancement, and recovery of biomass; - reclamation and improvement of strip-mined land; - forestry, nursery, and cultural operations; and - making public facilities accessible to individuals with disabilities. 2. Human services corps programs that include service in - state, local, and regional governmental agencies; - nursing homes, hospices, senior centers, hospitals, local libraries, parks, recreational facilities, child and adult daycare centers, programs serving individuals with disabilities, and schools; - law enforcement agencies and penal and probation systems; - private nonprofit organizations that primarily focus on social service such as community action agencies; - activities that focus on the rehabilitation or improvement of public facilities, neighborhood improvements, literacy training that benefits educationally disadvantaged individuals, weatherization of and basic repairs to low-income housing including housing occupied by older adults, energy conservation (including solar energy techniques), removal of architectural barriers to access by individuals with disabilities to public facilities, activities that focus on drug and alcohol abuse education, prevention and treatment, and conservation, maintenance, or restoration of natural resources on publicly held lands; and - any other nonpartisan civic activities and services that the commission determines to be of a substantial social benefit in meeting unmet human, educational, or environmental needs (particularly needs related to poverty) or in the community where volunteer service is to be performed; or 3. Programs that encompass the focus and services described in both paragraphs (1) and (2). |
||||
Home | Privacy Statement | FAQs | IFAP Search Help Copyright © 2003, IFAP. All rights reserved. |