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PROGRAM MEMOS (PM)
• Why do we have PM’s?
• How Many?
• Each PM, it’s purpose and
summary
WHY DO WE HAVE PM’S?
PM’s create a unified structure to the federal requirements.
Are required either in the Older Americans Act (OAA) or by the U.S. Department of Labor (DOL).
HOW MANY PM’S ARE THERE?
There are four CDA PM’s for SCSEP.
CDA does not prescribe how each individual Area Agency on Aging (AAA) should run their program as each AAA and community is different.
WHAT ARE THE CDA PM’S?
PM 10-19 Durational Limits and Transition Planning
PM 11-06 Grievance and Termination Policy Changes
PM 11-20 Participant Termination Policy PM 14-15 Authorized Break in
Participation Policy
PM 10-19 DURATIONAL LIMITS AND TRANSITION
PLANNING Increases job skills by encouraging rotation
in host agency assignments. Encourages practices to assist participants
in finding unsubsidized employment. Motivates participants to focus on the end
goal of unsubsidized employment. Provides step to be taken during the final
year on the program for participants.
Grievance
Each AAA has a grievance procedure that adheres to
22 CCR § 7400-7406 Must follow AAA grievance procedures CDA and DOL will only receive a grievance to ensure
that the grievance policy was followed – no determination is made DOL will only determine Civil Rights grievances, if
elevated to its level
Termination PM 11-20 provides a more in-depth, step-by-step
process
PM 11-06GRIEVANCE AND TERMINATION POLICY CHANGES
PM 11-06GRIEVANCE AND TERMINATION POLICY CHANGES
(CONTINUED)
General Grievance Procedure First Level of Resolution
AAA coordinator receives complaint , investigates, and makes determination
AAA Informal Administrative Review AAA Director receives complaint, investigates,
and makes determination Final Grievance Resolution
Complainant can request an impartial hearing before a officer/panel
PM 11-20PARTICIPANT TERMINATION POLICY
Required under Code of Federal Regulation (CFR), Title 20, Part 641.580(d) – 20 CFR 641.580(d)
Participant voluntary separation Participant involuntary separation Prohibitions Notification requirements Voluntary Separation Procedures Involuntary Termination Procedures
PM 11-20PARTICIPANT TERMINATION POLICY (CONTINUED)
Participant Voluntary Separation Unsubsidized Employment Relocation outside of the Planning and
Service Area Retirement Health Reason Institutionalization Family reasons Incapacitation or death
PM 11-20PARTICIPANT TERMINATION POLICY (CONTINUED)
Participant Involuntary Separation caused by Participant, Project, and For Cause
Prohibitions Project may not terminate participants solely on
the basis of their age. No upper age limit allowed.
Notification Requirements Must provide a written copy of the termination and grievance
policies Must verbally review termination policy and grievance procedures
during enrollment/orientation Tip – Have the participant sign a copy for your files
Must give a 30-day notice prior to involuntary termination Include detail on the reason(s) for termination Grievance policy should be included
Participants voluntarily separating should sign and date the Exit Form If not possible to get a signature, a case note is acceptable
Tip - include in the Exit Form comment box in SPARQ)
PM 11-20PARTICIPANT TERMINATION POLICY (CONTINUED)
Code of Federal Regulation (CFR) , Tile 20, Part 641.570(d) – 20 CFR 641.570 (d)
Permits a participant to request a formal leave of absence from SCSEP
Stops the Durational Limit (DL) clock, only for the break period Two types of leave
Voluntary Leave Administrative Leave
Authorized Breaks are unpaid Must be approved or declined in advance by the local SCSEP
Coordinator
PM 14-15AUTHORIZED BREAK IN PARTICIPATION POLICY
Voluntary Leave Up to 60 days Illness, Injuries, Estate Settlement, Marriage,
Family Care, Bereavement, Hospitalization
Administrative Leave Workers’ Compensation Administrative Review
Host agency closure Administrative Investigation
PM 11-20AUTHORIZED BREAK IN PARTICIPATION POLICY
(CONTINUED)
Enter all start and end dates for Authorized Breaks into SPARQ
Include case notes in the comment box
Extensions can be granted Maximum of 90 days Letter requesting extension must be submitted
to the SCSEP State Director PM outlines what requirements should be included
PM 11-20AUTHORIZED BREAK IN PARTICIPATION POLICY
(CONTINUED)
Where to find PM’s?CDA website
http://www.aging.ca.gov/PM/
Request a copy from your SCSEP Specialist
NOTE:
Your agency’s action on PM’s are reviewed during monitoring
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