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The IFAP online library contains technical publications, regulations, and policy guidance on the administration of the Federal Student Aid programs.
AwardYear: 1998-1999
EnterChapterNo: 7
EnterChapterTitle: Federal Work-Study Program
SectionNumber: 6
SectionTitle: Job Location and Development
PageNumbers: 45-48


[[Jobs are for FWS and non-FWS students--34 CFR 675.31]]
The Job Location and Development (JLD) Program expands off-
campus job opportunities for students who are enrolled in eligible
institutions of higher education and who want jobs regardless
of financial need
. This means that jobs may be located and
developed under the JLD Program for FWS and non-FWS eligible
students. The JLD Program encourages students to participate in
community service activities.

[[Purpose of JLD community service jobs]]
JLD community service jobs are designed to improve the quality of
life for community residents, particularly low-income individuals, or
to solve particular problems related to the needs of community
residents. Community services are those the school has identified by
working with local nonprofit, governmental, and community-based
organizations. Appropriate jobs are those in fields such as health
care; child care; literacy training; education (including tutorial
services); housing and neighborhood improvement; rural
development; and community improvement and jobs that provide
supportive services to students with disabilities. A school must
inform all eligible students of the opportunity to perform community
services and must develop and make available information about
community service opportunities.


JLD PROGRAM PARTICIPATION
----------------------------

A school that participates in the FWS Program is also eligible to
participate in the JLD Program. A school that has an executed
Program Participation Agreement (PPA) for the FWS Program is
able to participate in the JLD Program without any prior contact with
the U.S. Department of Education and without any revision to its
PPA. The school under the PPA agrees to administer the JLD
Program according to the appropriate statutory and regulatory
provisions.

[[Termination and suspension]]
If the Department terminates or suspends a school's eligibility to
participate in the FWS Program, that action also applies to the
school's JLD Program. Additional information about termination and
suspension is included in 34 CFR 675.37.


STUDENT ELIGIBILITY
----------------------

Any student employed in a job developed under the JLD Program
must be currently enrolled at the school placing him or her in a job.
A school may place in JLD jobs both students who do not meet
FWS student eligibility criteria and those who do meet that criteria.
However, using JLD funds to find jobs only for FWS students would
not satisfy the program purpose of expanding off-campus jobs for
students who want jobs regardless of financial need.


USE OF FWS ALLOCATION FOR JLD PROGRAM
------------------------------------------

Jobs located or developed under the JLD Program may be for either
a profit or nonprofit employer. When establishing or expanding a
program to locate and develop off-campus jobs, including
community service jobs
, a school may use up to the lesser
of the following two amounts:

- 10% of its FWS allocation and reallocation

- $50,000


USE OF JLD PROGRAM FUNDS
---------------------------

[[Paying the student]]
Federal JLD funds are used to pay a school's costs of establishing
and administering the JLD Program. The JLD funds are not to be
used to pay students whose jobs were located or developed through
the JLD Program. A job located and developed under the program
must be suitable to the scheduling and other needs of the employed
student and must, to the maximum extent practicable, complement
and reinforce the educational program or vocational goal of the
student.

[[Restrictions on using JLD funds]]
A school is expected to generate total student wages exceeding the
total amount of the federal funds spent under JLD. The school cannot
locate or develop jobs at the school or other eligible schools. JLD
jobs may be full time or part time. Jobs located or developed under
the program must not displace employees or impair existing service
contracts. The purpose of the JLD Program is to locate and develop
off-campus jobs for students during and between periods of
attendance, not to develop jobs for placement upon graduation.


FEDERAL SHARE LIMITATION
---------------------------

[[Federal share]]
[[Institutional share]]

The federal funds that a school sets aside from its FWS allocation to
be used for JLD activities may be used to pay up to 80% of the
allowable costs (listed below). The school must provide the
remaining 20% of allowable costs either in cash or in services. This
requirement, unlike the institutional share requirement for FWS
earnings, cannot be waived. The school must maintain records that
indicate the amount and sources of its matching share. Procedures
and records requirements for JLD are the same as those for all
campus-based programs. (See Chapter 5, Section 3.)


ALLOWABLE PROGRAM COSTS
--------------------------

Allowable costs of carrying out the JLD Program include

- staff salaries (and fringe benefits, if they are the same as those
paid to other institutional employees in comparable positions and
are not paid to a student employed through the FWS Program);

- travel expenses related to JLD activities;

- printing and mailing costs for brochures about the JLD Program;

- JLD telephone charges, including installation of a separate line for
off-campus employers;

- JLD costs for supplies, equipment, and furniture;

- newspaper or other types of advertising that inform potential
employers of the services JLD offers; and

- JLD workshops for students and employers.

[[Costs not allowed]]
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--the JLD director's
supervisor, for example.


FWS STUDENTS AS STAFF IN THE JLD PROGRAM
----------------------------------------------

A school may assign an FWS or a non-FWS student to work as a
staff member in the JLD Program, as long as the student is not
employed under the JLD Program. The prohibition against using
JLD funds to locate and develop jobs at any school prevents a school
from employing a JLD student (whether he or she is also an FWS
student or not) to work as staff in the JLD Program. This prohibition
does not, however, mean that the school is also prohibited from
employing any student (FWS or non-FWS) to work as staff in the
JLD Program. Student jobs as staff in the JLD Program are not
located and developed with JLD funds, and the student wages earned
working for the JLD Program are not reportable in the JLD section
of the Fiscal Operations Report and Application to Participate
(FISAP).

If a school places an FWS student as staff in the JLD Program, there
are some important points to note. The statute and the FWS
regulations prohibit the use of any funds allocated under the FWS
Program from being used to pay the nonfederal share of FWS
compensation to its students. Hence, the federal JLD funds may not
be used to pay the nonfederal share of FWS wages earned by a
student working as staff in the JLD Program. However, because JLD
allowable costs include staff salaries, the school would use its own
funds to pay the nonfederal share of the wages earned by an FWS
student working as staff in the JLD Program and would count those
funds in meeting the minimum 20% institutional share requirement.


JLD REPORTING ON THE FISAP
------------------------------

A school participating in the JLD Program must provide information
on the FISAP concerning the uses of the JLD funds and an
evaluation of the effectiveness of the JLD Program. The school
reports in Part V, Section D of the FISAP the federal expenditures
for JLD. In Part V, Section G, the school reports the total JLD
expenditures, institutional expenditures for JLD, number of students
for whom jobs were located or developed, and total earnings for the
students.


MULTI-INSTITUTIONAL JLD PROGRAMS
------------------------------------

[[Agreement with other eligible schools--34 CFR 675.34]]
A school that is participating in FWS may enter a written agreement
with other eligible schools for those schools 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
school 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 school must show that its own students have
earned wages that exceed the amount of federal funds the school
contributed to locate and develop those jobs. This fiscal information
must be reported on each school's Fiscal Operations Report and
Application to Participate
(FISAP).

If a school uses federal funds to contract with another school,
suitable performance standards must be part of that contract.
Performance standards should reflect each school's philosophy,
policies, and goals for the JLD Program. A school may not develop
performance standards, conditions, or terms that are inconsistent with
the statute or regulations. In all cases, the performance standards
should be clearly understandable, because they will be included in
the formal written agreement that each party must observe as part of
its responsibility within the particular arrangement.

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