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It was a pleasure to work with these students. They were a challenge. Each staff member gave his or her best to help them wherever help was needed. They worked beyond the hours designated and beyond the prescribed class schedules.

We thank the State Department of Public Instruction for selecting us as the institution privileged to work with these young women. We thank MES C for their fine selection, counseling, follow-up, and cooperation.

EXHIBIT B-3

[Reprinted from Employment Service Review, May 1966 U.S. Employment Service, U.S. Department of Labor]

PARTNERSHIP IN TRAINING

(By A. Lauren Rhude1)

On the morning of June 17, 1963, more than 1,000 employees of the Armour & Co. Packing Plant in Sioux City were out of work. Sioux City had lost its largest, most solidly entrenched employer.

During the 3 years since that closing, a crisis in local unemployment turned into a success story. Sioux City met the crisis and now is experiencing an employment level higher than before the Armour closing.

Part of the success story is written in outstanding Manpower Development and Training Act programs, several of which were conducted at Nettleton Business Training College, a private business school.

Through the cooperation of the Iowa State Employment Service office in Sioux City and the State Department of Public Instruction, Sioux City plant employees were among the first to benefit from the start by retraining available under MDTA.

At the time of the Armour closing, a citizens committee was formed to find ways and means of retraining many of the plant employees and placing them in other occupations. Serving on this committee were the Manager of the Sioux City Employment Service office and the President of NBT College.

TRAINING STARTS

After testing and consultation with many of the Armour employees, various training programs were developed in Sioux City under MDTA. The first program conducted at NBT College for Armour employees started in August 1963, with 15 of the former plant personnel enrolled in a stenographic class. The college already had some experience with MDTA trainees by that time, however, as the first such students had enrolled in February 1963.

Since that first class, approximately 200 students have been trained by NBT College in stenographic, general office clerk, and bookkeeping skills.

Screened by the employment office, the students in these group training programs have compiled impressive records. In addition, there have been a number of individual referrals to programs at NBT College under the plan for less than full class training referrals.

ACCEPTED BY CLASSMATES

One of the reasons the MDTA programs have been so successful is the acceptance and cooperation MDTA students have received from their classmates at NBT. For, in addition to training the unemployed for various skills, MDTA is designed to provide opportunities for personal development to improve employability and job prospects.

The enrollment at the college is approximately 300, providing the MDTA students with an opportunity to integrate into various classes and courses available at the 2-year school of business. Some of the specific courses available, such

1A. Lauren Rhude is President, Nettleton Business Training College, Sioux City, Iowa.

as the finishing course for girls and the grooming and development course for the boys, have helped these students greatly in developing self-confidence and in meeting personal and social obligations. MDTA trainees have also participated in school-sponsored extra-curricular activities and have achieved positions of honor and responsibility.

The great majority of MDTA students have been serious minded and conscientious. Placement of most of these students has been in the fields for which they were trained, and many of them are holding very responsible jobs in private business.

The Iowa State Employment Service in Sioux City has an outstanding record record of placing MDTA students in a variety of programs. The experience of this school has been that not only have highly marketable skills been attained by MDTA students, but also they have been given an opportunity for personal development to achieve complete acceptance in the field of business.

EXHIBIT C

UNDER CONTRACT TRAINING

This is one of the many examples of constructive cooperation by a business school with a State Employment Service and the Vocational Rehabilitation Administration. Society and the individual have benefited from the educational program provided through "under contract training" with a business school after testing and counseling by Employment Service and Vocational Rehabilitation counselors.

Similar successful programs of “under contract training" with business schools are authorized by such Federal programs as—

1. Indian Adult Vocational Education; 25 U.S.C. 309.

2. Vocational Rehabilitation Act of June 2, 1920, as amended; P.L. 83-565. 3. Manpower Act of 1965; P.L. 89-15 [See Sec. 231].

4. Economic Development Administration; P.L. 89-15 [See Sec. 241].

5. Economic Opportunity Act of 1964 ; P.L. 88-452 [See Sec. 103(b)].

6. Government Employee's Training Program (P.L. 85-507) 5 U.S.C. 2301– 2319; [See Sec. 2302 (7) ].

7. Vocational Education Act of 1963 (P.L. 88–210).

(For a free Directory listing nearly 500 quality business schools, write to United Business Schools Association, 1101 Seventeenth Street, N.W., Washington, D.C. 20036.)

[From the St. Petersburg (Fla.) Times, May 5, 1966]

FOR MRS. PENNEWILL, VOCATIONAL AID THE CLIMB TO REHABILITATION (By Nancy Osgood)

A swindle, crushing defeat and a woman with intestinal fortitude. These strange bedfellows unite in a melancholy tale with a surprise ending. Seven years ago, a prospering Pennsylvania builder uprooted his wife and four children to come to St. Petersburg. He'd been talked into a contracting partnership by a family friend.

Six months later, the "friend" took all they had. There was not even enough left to sue him. Bills piled high. Creditors demanded payment. Gloom stalked the family.

In desperation the mother decided to seek employment. But the story is Juanita (Mrs. A. L.) Pennewill's to tell.

"That was when I found out I couldn't do very much. After high school, I'd had some training in interior decoration. That ended my education. At 17 I developed agonizing back trouble. After months of specialized treatment, I was given a spinal fusion with one in a thousand chances of ever being able to walk again. But I did recover.

"A year after the operation-at 21-I was married and have been able to give normal birth to our four children. I worked a short while after marriage. But when our problems began, I'd been a stay-at-home housewife and mother for 19 years.

"When I sought work through the Florida State Employment Service (FSES), I was limited by much more than inexperience. Because of my unstable back, aggravated by a tendency to overweight, I could not take a job that required standing, stooping or bending.

"I also had dermatitis of the hands. For 10 years they had cracked open, I lost nails, had to use medication and wear gloves constantly. That eliminated any job having to do with food. Besides, I'd lived so long on cortisone for allergies, I'd become a cortisone cripple-thought I couldn't live without it."

Here was an impasse a desperate need to earn, by a person immediately unemployable.

The turning point came when FSES referred 40-year-old Mrs. Pennewill for help to the Division of Vocational Training (DVR), State Department of Education. This agency's purpose is the development of those individuals whose mental or physical disabilities cause limitations of activity, which in themselves are a vocational handicap.

All persons of working age (16 and over) who fall within this category, are entitled (without regard to income) to three services: counseling, training in any vocation, and selective placement. Also available to those in economic need (others are expected to pay) are medical and surgical services, prosthetic appliances, training supplies and (if need be) maintenance during training.

These DVR functions were explained by senior counselor Marcus N. Cobb, whose client Mrs. Pennewill became. General procedures follow the course he outlined for Juanita.

"First we sent her for a complete medical diagnosis." (Based on her special needs, she saw an orthopedist, a dermatologist, an internist and a psychiatrist. The thorough testing over a six-week period cost DVR $115.)

"Aptitude testing (at FSES) came next. Mrs. Pennewill showed superior intelligence and manual dexterity-proved superior across the board. When her abilities were narrowed down to bookkeeping and accounting, we sent her to Bixby Business College for a year (January-December, 1965)."

Cobb spoke in glowing terms of Juanita's progress. "In the first three months of training she lost 17 pounds of her own volition, her dermatitis cleared up and she made better than average grades all through school." (She also withdrew from cortisone.)

Juanita does not take full credit for her achievements. "I was rich in friends. At Bixby I wasn't just a student. Everyone there as well as Mr. Cobb seemed to take an interest in me as a person. It was wonderful."

Counselor Cobb said that within a week of completing her training, his client was engaged as full-time bookkeeper by the Pinellas Seafood Co. She'd been recommended by the owner's daughter, Barbara Kinney, a fellow student at Bixby.

Happily situated in a permanent job, Juanita Pennewill can look forward to an end to bills and to helping put her children through college. (Richard, 19, is a junior college student; Ann, 17, is in high school; and David, 12 and Jimmy, 7, respectively are in the sixth and second grades.) A happy sidelight is that his mother's job will enable David, a straight-A student, to join fellow safety patrol captains, when on Friday, May 13, they leave for a four-day tour of Washington, D.C.

Among Mrs. Pennewill's staunchest supporters is John I. (Jack) Goddard, president of Bixby Business College, where many DVR clients are trained. "She's doing brilliantly," he boasted.

The opportunities available to those who qualify for vocational rehabilitation, were summed up by counselor Cobb:

"From July 1, 1965 to Feb. 28, we had 217 persons in training; in the same period, 87 persons were in some form of physical restoration for the removal or diminishment of disabilities; 23 were in some phase of training plus medical treatments; and 245 cases were closed as 'successfully employed'.

"There is nothing we can't do if it makes sense. *** There is no limitation through age alone. * * * Service rendered by the Division of Vocational Rehabilitation is not welfare. It's a business proposition. If we can put people to work, we keep them off welfare and make taxpayers of them."

The Division of Vocational Rehabilitation, State Department of Education,' Max Hofmeister, director, has offices at 3820 Central Ave. Telephone 896-4177.

65-922-66- -21

EXHIBIT D

U.S. DEPARTMENT OF LABOR,
BUREAU OF EMPLOYMENT SECURITY,
Washington, D.C.

States Employment Service, Program Letter No. 1758, January 26, 1965.
State Employment Security Agencies.

:: Procedures Governing MDTA Training on Less Than a Class-Group Basis, MDTA Series No. 143.

Farence: USESPL No. 1666.

arnose: To clarity procedures for preparing training proposals for funding less than class-group referrals.

This letter revises previously issued instructions on providing MDTA training ot less than a class-group basis.

Many occasions arise when it is not practical to organize an MDTA course to train workers for a specific occupation, but circumstanes are appropriate for the inclusion of one traineee, or a few MDTA trainees, in an existing public or private training program. The individual method of referral outlined herein is designed to supplement existing class-group referral procedures, which should continue to be used whenever possible. The procedures follow closely, with modifications, those contained in chapters III and IV of the MDTA Handbook.

When it is determined that an individual unemployed worker needs training in an occupation for which no suitable MDTA course is available in his locality. nor are there plans to develop such a course during the next 45 days, the local office should ascertain whether the individual can be included in a course being Offers in another location in the State. This may be determined by communicating with the MDTA coordinator in the State office. To facilitate out-of-area referral. State agencies should circulate to all local offices lists of MDTA courses which are being set up throughout the State.

In instances where demand in an occupation is scattered and apparently not ent to justify the establishment of separate training classes with 10 or more trainees in a number of different locations, the development of centralized area or statewide training projects should be considered.

In both of the above situations, trainees would be provided transportation and subsistence allowances to enable them to attend courses beyond commuting distance from home.

The following procedure applies to situations where (1) training is needed in an occupation for which there is not sufficient demand throughout the State for establishment of a statewide course; (2) a project has little likelihood of commencing within the 45-day period prescribed above; or (3) an MDTA training course already has started, the classes are full, or, for other reasons, it is not practicable to include an individual.

1. Selection of Trainees and Determining the Training Need.-Persons may be selected for referral to training on an individual basis when counseling results in a substantive determination that the individual cannot reasonably be expected to secure appropriate full-time employment without training assistance under the Act. Particular attention should be paid to (1) applicants not qualified at the entry level or higher for any suitable occupation in which there is reasonable expectation of employment; (2) applicants qualified only in occupations which have changed so that the workers' present abilities to perform the work are obsolete or inadequate; (3) applicants qualified only in occupations which characteristically offer minimal employment stability, e.g., work that is seasonal or transitory; (4) handicapped persons, older workers, or educationally deficient persons who, because of specialized training needs, could not readily be accommodated in MDTA training courses organized on a class-group basis; and (5) persons living in rural areas or small communities in which there is limited occupational demand or training opportunities.

Where training facilities have continuous courses and entrance into such courses is possible for regular students at any time, MDTA trainees should be enrolled in these courses the same as any other trainee. Otherwise eligible workers who are currently pursuing training under their own auspices will not be "blanketed-in" for payment of training allowances, training costs, or other MDTA benefits.

The training needs of individuals should be determined by interviewing, testing and counseling, taking into account such factors as the applicant's prior

education, work history, interests, aptitude, motivation, and availability for training or employment outside of the area in which he lives.

2. Determination of the Occupation for Which Training Is To Be Given.-The counseling interview with an individual may suggest a range of occupations for which training would be suitable. Within this range, a determination must be made in consultation with the trainee as to the most appropriate specific occupation, taking into account the labor outlook for various occupations, duration of training to qualify for the occupation, and availability of training facilities.

The "reasonable expectation of employment" provisions of the Act must be satisfied regardless of the referral method. To identify occupations for the individual referral method, State and local offices should utilize fully all pertinent sources of data of the employment security system, including such indicators as unfilled job orders, area-skill surveys, and employer relations representatives' reports. Reasonable expectation of employment will be considered to exist if there is an indication that employment opportunities in the occupation exist in the community, within the State, within bordering areas of adjoining States, or on a nationwide basis.

Reasonable expectation of employment will also be satisfied in the following circumstances:

(a) The applicant for training has a written job offer from a prospective employer which also attests to the employer's understanding that the worker will not be available until completion of a course of training. In such cases, it should be ascertained that the applicant has the necessary qualifications to benefit from training and could adjust to the occupation for which training is proposed. Care should be exercised to prevent furthering discriminatory hiring. practices of employers.

(b) The individual is to be referred to a training facility which has a successful record in the placement of its students in the occupation for which training is proposed.

While it would not be practicable to discuss each individual referral with local MDTA advisory committees, the committees should be advised of the purpose and progress of less than class-group projects.

3. Preparation and Approval of Less Than Class-Group Training Proposals.— Less than class-group projects will be authorized on a fiscal year basis. Once during each fiscal year States may submit on Form MT-2, Application for Occupational Training Program Under the Manpower Development and Training Act: Institutional, to the Federal review team for approval, a project proposal indicating the estimated number of trainees who are to be referred on a less than class-group basis during that fiscal year. Such proposals should be prepared jointly by the State employment security and vocational education agencies, in accordance with current MDTA procedures. The approval of a Form MT-2 to cover referrals to less than class-group projects on an annual basis will eliminate the need for frequent Federal review meetings.

The Form MT-2 should show estimates for training, allowances, subsistence, and transportation to cover the full length of training for all less than classgroup referrals that are expected to be made in the current fiscal year. Fiscal year breakdowns should be shown where pertinent. Forms OE-4000, Expenditures for Occupational Training, and OE-4014, Guide for Preparation of Training Plan, are not required as attachments, but a statement should accompany the Form MT-2 explaining the basis for the estimates.

Proposals should be reviewed periodically to assess estimated referrals and costs in relation to acual experience. As adjustments are made in training plans, either to increase or decrease the original estimates of referrals, an amended Form MT-2, with supporting documents, should be submitted so that additional funds may be obligated, or excess funds may be deobligated. Appropriate pre-audits and post-audits will be made by Federal authorities.

Each Form MT-2 for a less than class-group project should be numbered as specified in USESPL No. 1666.

4. Referral of Individuals to Training.-Applications for the referral of individuals to training should be developed by local employment service and vocational education authorities and submitted to State agencies for approval on Form MT-3, Individual Certification for Manpower Training (copy attached). The signature of the State employment security agency administrator or his designee constitutes approval of the individual certification (Form MT-3). The

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