The WtW grants program, while fairly straightforward in its mission and intent, has some complex administrative provisions. For many grantees, some of these provisions, and the issues they posed, became a central focus of early program startup, and in some cases efforts to resolve these issues continued over much of the first year. Some of the administrative issues involved state distribution of funds, local grantee contracting procedures and the development of new service capacity, program reporting and concerns about audits, and decisions about how to apply complex WtW eligibility criteria.(11)
State Distribution of WtW Funds. In some states, federal WtW formula funds were not available immediately to the local programs, although all state WtW agencies obligated funds to SDAs within 30 days of receiving federal award notification, as required by law. In most sites visited, it took about six months after local grantees were notified of their funding for them to enroll their first participants in a program activity. Some of this delay reflected decisions that had to be made at the state level, such as getting legislative authorization for funds required as a match for the formula grant.
Local Contracting Procedures. Several procedural and administrative factors at the local level also had to be dealt with before programs could begin operating. For example, many PICs and SDAs decided to use competitive procurement procedures to select WtW service providers, just as they have for JTPA-funded services. The process of issuing requests for proposals, reviewing bids, selecting contractors, and negotiating contracts typically takes several months. The service delivery contracting process could not begin before the SDA had authority to spend the federal (and, usually, state) funds. If there was a delay at the state level in actually releasing funds, the local contracting process added more time to the operational start-up schedule.
Concerns About Reporting and Auditing. PICs and SDAs are especially sensitive to federal reporting and financial requirements, and their administrators and board members take a cautious approach, to avoid audit exceptions that might arise from errors in determining eligibility and authorizing allowable expenditures.(12) WtW program rules set specific eligibility criteria and limit
the circumstances under which education and training can be funded by the WtW grants. These rules raised many questions, and until they could be resolved, PICs and SDAs proceeded cautiously, to avoid the possibility of fiscal audit exceptions.
Building Capacity in New Service Deliverers. Startup of WtW programs has been slow, in part because WtW funds in many sites are being used to develop entirely new programs. Many competitive grantees and subcontractors, particularly nonprofit CBOs, are developing new programs with the WtW funds, rather than using WtW funds to enhance or expand programs already operating with TANF or JTPA funds. Some grantees are not traditional JTPA or TANF contractors and are expanding their services or developing new ones specifically in response to the availability of WtW funds. Several of the grantees visited, for example, hired new staff, entered into leases for facilities, and developed special management information systems to run their WtW programs. Some grantees with multiple service provider contractors sponsored special technical assistance and training sessions for their providers, to help them start their operations.
Applying Complex Eligibility Criteria. The complex eligibility criteria in the WtW legislation are the most common problem local program operators faced in the first year and, perhaps, the most important factor that has slowed implementation and limited overall enrollment to date. Grantees have encountered particular difficulties applying the criteria pertaining to long-term receipt of assistance and educational barriers to employment.
Individuals can be enrolled in WtW programs in the "70 percent category" as long-term welfare recipients only if it can be verified that they have received assistance for at least 30 months, a verification that has been difficult for many welfare agencies and WtW program administrators. Welfare agencies' data systems are still being restructured to allow efficient identification of an individual's lifetime cumulative receipt of benefits for TANF, which would allow verification of the 30-month criterion. Until that system capability is available, most local WtW programs must, instead, rely on welfare agencies' verification of the length of the current spell of benefits. As a result, some individuals who have received assistance for more than 30 months in multiple spells cannot conclusively be deemed eligible for WtW. This problem is one factor constricting the flow of entrants to WtW programs.
Enrollment problems and delays have also arisen from the eligibility criterion, in effect under the WtW legislation as originally enacted, that requires enrollees to lack both a high school diploma and adequate skills in math or reading. Individuals who have a diploma but lack basic skills have been ineligible for WtW services unless they have a substance abuse problem requiring treatment. This is the most common problem mentioned by local program administrators and staff in the exploratory site visits. In addition to preventing enrollment of some individuals, the education criterion delays enrollment of others. Individuals who lack a high school diploma must be tested to confirm their low skills, even when an initial assessment by the welfare agency or the WtW program has clearly determined that they have serious barriers to employment.
Staff in most of the 22 grantee organizations strongly believe that many individuals in their areas have serious barriers to employment and could benefit from the intensive services allowed under WtW, but do not meet the strict eligibility criteria in the original legislation. As some said, they "qualify under the spirit, but not the letter, of the law." Program staff and administrators expressed confidence that, if the education criteria for eligibility were modified, enrollment would increase.(13)