Second of all, targeting enforcement, exactly who is going to come in and tell an SDA what to do when they clearly have not done what JTPA requires. I recognize that the JTPA law is different from the CETA law. CETA required clearly equitable services to significant segments. JTPA does not require that. But it seems to require the same thing because, first of all, it requires equitable services to both AFDC recipients and youths on one hand, and, on the other hand, it requires nondiscrimination against certain protected groups. We feel that those two requirements mandate what CETA mandated under its equitable service to significant segments of the population or target groups. From what we have seen from many of the service delivery areas in the State, they also feel the same way. Los Angeles County has broken rank. In their original proposed program the significant segments were not representative of who should be receiving the services in Los Angeles County. We're not here to debate whether or not GR recipients are eligible people under JTPA; that goes without saying. I think you have 558,000 people in Los Angeles County who are economically disadvantaged and are eligible, but you only have 4,000 slots. So when you're going to split the pie up, we feel that it should be on an equitable basis and not totally inequitable, such as what we have here in Los Angeles. In exhibit A of my testimony, there is a chart which pretty much gives you the population characteristics breakdown. I won't go into all the elements here, but it talks about, in the first column, who is actually economically disadvantaged. The second column under client characteristics are the GR recipient characteristics. The fourth column is the original plan approved by the State and the PIC on September 30, 1983. The final column is what currently the program is targeting in terms of individuals who should be receiving services. Despite the changes that the county has made in the program, in large part due to State intervention and even though we didn't agree with the findings, I think some changes did occur-in large part due to the lawsuits and administrative actions. We still have the program seeking to serve 72 percent men, 28 percent women, only 3 percent AFDC recipients, 29 percent black, 52 percent Hispanics, and no targets for limited-English-speaking people. Those are not good figures. We don't agree with them and we feel that they should be changed. We're very disappointed with the targeting enforcement provided to us by the State JTPA office and actually the lack of enforcement on that level. We don't think that the State monitoring system is adequate. Granted that Los Angeles County has changed its focus from originally 100 percent GR to 90 to 75 percent, and now they're proposing to go as low as 50 percent; that does not solve the problem. San Francisco County, in comparison, is serving 3 percent general assistance recipients. We believe Los Angeles County should serve an equal number, which is approximately 3 to 5 percent, and then should open up the slots to other eligible groups. On February 7, last week, the Legal Aid Foundation of Los Angeles, Mexican-American Legal Defense Fund, and the Western Center on Law & Poverty filed on behalf of unemployment insur ance recipients and AFDC recipients who could not get into the JTPA program here in Los Angeles County. We hope that on the Federal level we'll get better response to our complaints than we have been able to get on the State level. One final point, which was raised in the administrative complaint that was filed on February 7 and which is illustrated in exhibit C of my testimony, is the fact that the county's plan seems to focus on AFDC-U recipients. They talked to you earlier about the program that happened last year where it was very successful with AFDC-U. I must point out that AFDC-U recipients are generally twoparent families and those individuals who obtain training in twoparent families are generally the men. There is almost no mention of AFDC family group recipients which is generally women, single family heads of households, who really are overlooked and who appear to have been of primary consideration of not only JTPA but FESA, and are just not receiving adequate services under the Los Angeles County plan. I'm looking at the PIC once again. The PIC may be adequately represented in some levels. Clearly 51 percent of the people are from the business sector as mandated by JTPA, but my reading of the PIC list show only two women out of about over 20 members, and I don't think that that is adequate. Of course, JTPA doesn't require, as CETA did, that there be once again equitable numbers of eligible groups on the PIC. But we feel that, in large part, we need to turn around the other PIC members in order to get more adequate services to women, AFDC recipients, from family group persons over the age of 45, and limited-English-speakers who are just not adequately served by the current county plan. Thank you. Mr. HAWKINS. Thank you, Ms. Estrada. Without objection, your full testimony will be placed in the record, as it was submitted. Next is Mr. Boyle, the chair of the Los Angeles Regional Coalition of Service Providers. [Prepared statement of Carmen Estrada follows:] PREPARED Statement of CarMEN A. ESTRADA, Western CENTER ON LAW AND POVERTY, INC., LOS ANGELES, Calif. Congressman Hawkins and members of the subcommittee: My name is Carmen A. Estrada. I am an attorney with the Western Center on Law and Poverty in Los Angeles, California. On behalf of the Center and our clients we welcome the opportunity to present our comments on Los Angeles County's implementation of the Jobs Training Partnership Act [JTPA] for the 1983-84 program year. Los Angeles County originally focused its total job training program on county welfare recipients. The county has since modified the numbers of county welfare recipients in its JTPA program but continues to serve a significant number of these individuals in its program. By focusing the total program on this one economically disadvantaged population, the County is overlooking the job training needs of many thousands of other County residents: Recipients of Aid to Families with Dependent Children [AFDC], recipients of unemployment benefits, women, handicapped, persons over the age of 45, the limited-English-speaking and others not adequately included in the current County JTPA Program Plan. The Los Angeles County Service Delivery Area [SDA] has over 558,320 persons who are economically disadvantaged for the purposes of JTPA job training. The County welfare population is only 3 to 5 percent of the County's economically disad vantaged. Despite this fact, the county has been allowed to primarily focus its job training program on this population by the State JTPA office. It is our belief that the JTPA program target population does not reflect the population characteristics of those who should be receiving the training services if it were distributed on an equitable basis. For example, the original program participant plan targeted for training persons with the same characteristics of persons on the County welfare program: 72 percent men and 28 percent women, 49 percent Black, 21 percent Hispanic and 2 percent AFDC recipients. These numbers contrast sharply with the characteristics of the economically disadvantaged population which consist of: 55 percent women, 15 percent black, 52 percent Hispanic and 11 percent AFDC recipients.1 The County revised their Participant's Program Plan in October 1983. The ethnic targets were changed to more accurately reflect the ethnic population (29 percent black and 52 percent Hispanic participants) but nothing was done to change the gender targetsthe County plan still calls for training 72 percent men and 28 percent women. Adult AFDC recipients were increased from 2 percent to 3 percent of the targeted participants. The target for persons over the age of 55 was increased slightly. Finally, there is no target for persons with limited English proficiency. The lack of a target for this group seems shocking in a county where there are approximately 200,000 people with limited English skills. However, county planners apparently did not take this fact into consideration when developing the plan; rather, it more than likely considered that only 11 percent of the County welfare population had limited English speaking skills. Overall, these are but a few of the serious defects which we feel should be remedied in the current County plan. On October 6, 1983, our organization made a request for an investigation to the Employment Development Department as provided for under the California Unemployment Insurance Code, section 15029. We raised numerous issues regarding the County plan which we felt did not comply with the State JTPA law. After several months of investigation the Director of the Employment Development Department released his declaration of findings which held that the issues we raised did not violate the provision of the State JTPA law. As a result, our concerns were never brought to the attention of the State Job Training Coordinating Council. I am attaching a copy of all correspondence between our office and the State agency overseeing JTPA.2 The Director of the Employment Development Department, in responding to our letter expressing displeasure with the declaration of findings, justified allowing the County of Los Angeles to continue on its course because he believed that the Governor has "limited enforcement authority." On the one hand, the Director of the State Department indicates that the SDA must meet general basic requirements in order to receive federal funds and that "recipients of payment of [AFDC] and eligible school dropouts be served on an equitable basis.” On the other hand, he states the following: "The role of the Governor, as delineated by Congress, is to designate the Service Delivery Areas, certify the Private Industry Council, and approve the job training plan which is to be developed and prepared at the local level... The job training plan need only satisfy the general guidelines established by Congress." He further underscores the limited powers of the Governor: "So long as a Service Delivery Area operates its program to deliver employment and training services within the described broad guidelines the Governor has limited enforcement authority." (Emphasis added). Despite the County of Los Angeles' blatant failure to serve women, AFDC recipients and other eligible population groups the State agency charged with overseeing local JTPA programs has failed to take any significant action on what, to us, is an obvious failure to meet the spirit and intent of the federal job training laws. On February 7, 1984, our organization, joined by the Mexican American Legal Defense and Educational Fund and the Legal Aid Foundation of Los Angeles, filed an administrative complaint with the United States Department of Labor, Office of Civil Rights, alleging discrimination against women, AFDC recipients, and persons over the age of 45.3 We hope for a favorable determination in that matter since it is clear to us that JTPA mandates equitable job training to AFDC recipients, women, and other categories. Unfortunately, the State JTPA agency did not share in our conclusions. 1 See chart, exhibit A. 2 Exhibit B. 3 Exhibit C. RECOMMENDATIONS The goals and standards of JTPA are laudable in stating that various segments of the economically disadvantaged population are to be served on an equitable basis. Unfortunately, our experience in Los Angeles illustrates that the statutory standards enunciated in JTPA is insufficient. Los Angeles County has bypassed the obvious intention of Congress to serve the poor equitably, they have accomplished this by targeting County welfare recipients, a segment of the population that is not representative of the economically disadvantaged people in the County. The Comprehensive Employment Training Act [CETA] was very specific in requiring that persons be served in proportion to their numbers in the poverty population. Specific language mandating equitable services to JTPA eligible populations would give guidance to SDA's targeting significant segments in their area. Our experience in Los Angeles demonstrates the inadequacy of the State monitoring mechanism. Our Governor's "limited enforcement authority" has allowed the continuation of the Los Angeles County program as currently structured and may very well lead to additional counties following their lead. We do not believe that Congress intended that JTPA funds be used to save local counties money in the administration of their county welfare programs. When such an abuse occurs, it is important that an adequate complaint mechanism brings these matters to the attention of an enforcement authority that will take remedial action and not stand back and allow the program to continue despite obvious irregularities. Under CETA, the Department of Labor (DOL) had both the authority and experience to monitor programs. Delegating this authority to the State has resulted in a laisez-faire attitude which has allowed the largest SDA in the state to administer a program which wholly circumvents the intent of JTPA. CONCLUSION The goals of the JTPA program have great promise. The implementation of these goals in Los Angeles County has been a disaster. The County's program as structured excludes great numbers of women, AFDC_recipients, non-English speaking persons and others which were served under CETA and are eligible populations under JTPA. The JTPA equitable service standards should not be so vague as to allow what has occurred in Los Angeles County to occur elsewhere. We urge the subcommittee's continued review of the Los Angeles County SDA. All that we ask is that JTPA equitably serve the various segments of the poor and give them the opportunities that Congress envisioned for work by which they can support themselves and their families. Thank you. (Exhibits A, B, and C appear in the appendix.) STATEMENT OF HOWARD BOYLE, CHAIR, LOS ANGELES Mr. BOYLE. I appreciate the opportunity to testify this afternoon on behalf of the Los Angeles Regional Coalition of Service Provid ers. Our coalition is composed of community-based organizations and school districts engaged in job training as subcontractors with the county of Los Angeles. We provide training for eligible local residents and operate within the parameters of the county's annual plan and the implementing directives from the County department of community services. Our coalition was formed 3 years ago by service providers. It is incorporated with by-laws, officers and standing committees. We are not sponsored by Government and do not receive any funds from Government at any level. Our association has grown to become the largest coalition in California of CBO's and school districts engaged in job training under the Job Training Partnership Act. Because our coalition is relatively of recent origin, I want to mention a few of the organizations that belong to the coalition: The Los Angeles Urban League; the Mexican-American Opportunity Foundation; the Chinatown Service. Center; the Pacific-Asian Consortium in Employment; the Career Planning Center; the Los Angeles; United Community Housing and Development, formerly Catholic Archdiocese of Los Angeles; Cal State University, Los Anegeles; United Community Housing and Development, formerly known as Young Israel; the West San Gabriel Valley Consortium; the East San Gabriel Valley Consortium, and many, many others. With that introduction, I would like to make some general observations regarding the current Los Angeles County plan of targeting general relief recipients in its JTPA program. I want to make it very clear that we, as service providers, are not opposed to serving general relief recipients provided that they are served along with other eligible groups and that their presence will not force us to exclude other eligible persons from enrollment and participation. This sadly is not the case today. No. 2, we believe that the current county general relief training program is in serious conflict with the intent of Congress in the JTPA legislation, which was to serve many segments of the poverty population and not just concentrate on one segment. No. 3, the Job Training Partnership Act should not be used by local government officials as a convenient device to reduce their budgetary problems and by so doing so slamming the door in the faces of eligible poor people who should receive job training under JTPA. The problems of implementing the current county general relief training program at the community level have been devastating and frustrating. I want to comment on some statements that were made this morning by earlier witnesses referring to the assessment process that takes place before general relief recipients are referred to subcontracting training sites. Let me state very clearly that there is no assessment of the general relief recipients. As recently as 3 weeks ago, a service provider requested 40 general relief recipients from the county and requested that they be assessed as to their job skills. The county referred 29 general relief recipients to the agencies, none of whom had gone through an assessment process, and only 5 were found by the agency to have appropriate skills for their particular training program. At no point before the current program was adopted were subcontractors consulted on any aspect of the program plan. We were simply told in a threatening manner that the board of supervisors had adopted the general relief training program and we had better conform with it or not be funded by the county. The County department of community services began to negotiate with service providers, proposing a completely unrealistic participant cost of $1,488 which was supposed to include all costs, even general relief stipends. Since most general relief recipients receive $228 per month and these payments were to be charged to a subcontractor's participant costs, it was clear that no service provider could keep a general relief recipient in training for more than 8 to 12 weeks. As a result of contract negotiation, the range of most participant costs was finalized at between $1,488 and $2,600, including general relief stipends. These low participant costs, more than anything else, contributed to a design which dictated widespread |