ADVISORY	:	TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 17-01
TO	:	ALL STATE WORKFORCE LIAISONS ALL STATE WORKFORCE AGENCIES ALL STATE WORKER ADJUSTMENT LIAISONS ALL ONE-STOP CENTER SYSTEM LEADS
FROM	:	EMILY STOVER DeROCCO Assistant Secretary
SUBJECT	:	Incorporating and Utilizing Grassroots, Community-Based Organizations (CBOs), Including Faith-Based Organizations (FBOs), in Workforce Investment Activities and Programs

1. Purpose. To inform the workforce investment system about the Department of Labor's Center for Faith-Based and Community Initiatives (CFBCI) and its purpose; and 2) To request that states take actions to broaden the number of grassroots community-based organizations, including faith-based organizations, which partner with Local Workforce Investment Boards and One-Stop Career Centers.

2. References. The Workforce Investment Act of 1998 (WIA or the Act) (Public Law 105-220, 29 U.S.C. 2801 et seq.); WIA Final Rule, 20 C.F.R. parts 652, 660-671 (65 F.R. 49294 (August 11, 2000)); Interim Final Rule implementing the nondiscrimination and equal opportunity provision (section 188) of WIA, 29 C.F.R. part 37 (64 F.R. 61692 (November 12, 1999)); Planning Guidance and Instructions for Submission of the Strategic Five-Year State Plan for title I of the Workforce Investment Act of 1998 and the Wagner-Peyser Act (64 F.R. 9402 (February 25, 1999)); Final Unified Plan Planning Guidance (65 F.R. 2464 (January 14, 2000)); Executive Order 13198; "Rallying the Armies of Compassion" (www.whitehouse.gov/news/order); "Report on an Unlevel Playing Field: Barriers to Participation by Faith-Based and Community Organizations in Federal Service Programs" (www.whitehouse.gov/infocus/faith-based).

3. Background. On January 29, 2001, Executive Order 13198 was issued by President George W. Bush, creating the Office for Faith-Based and Community Initiatives in the White House and centers in the Departments of Labor, Health and Human Services, Housing and Urban Development, Education, and Justice. The purpose of the Office and its centers is to make government a partner with local faith-based and community-based organizations in addressing social issues.

   The Executive Order charged the cabinet centers with identifying statutory, regulatory, and bureaucratic barriers that stand in the way of effective partnerships between faith-based and community-based initiatives and the government, and to ensure, consistent with the law, that faith-based and community-based grassroots initiatives have an equal opportunity to compete for federal funding. Each departmental center performed an audit and issued a report on departmental policy affecting faith-based and community-based organizations. The Department of Labor audit discovered that both faith-based and community-based grassroots organizations are often not utilized as partners in the workforce investment system. This letter requests that states take appropriate actions to incorporate faith-based and community-based organizations into the One-Stop system and local Workforce Investment Board activities.

4. Connecting with the Workforce Investment System. Local Workforce Investment Boards and State Workforce Agencies work to respond to the needs of businesses and workers in developing the local workforce. To help create effective strategies, Local Workforce Investment Boards and State Workforce Agencies are encouraged to utilize two different facets of faith-based and community-based organizations: their leadership and their services. First, local leaders of grassroots faith-based and community-based organizations can offer a crucial perspective on what unemployed and underemployed individuals need to join the workforce and become self-sufficient. Second, grassroots organizations can be powerful partners as service providers because they often:

   1. Exist as part of religious congregations or other established networks that are already trusted and credible neighborhood and community institutions.
   2. Use volunteers to leverage program dollars for maximum effectiveness.
   3. Provide services in the context of personal attention and relationships that can guide and support program participants engaged in major life transitions, including the transition into the workforce.
   4. Share common goals with the Local Workforce Investment Board and One-Stop System.

   State Workforce Agencies are encouraged to take into account the importance of faith-based and community-based organizations and take the actions listed below in order to facilitate partnerships. Additionally, ETA will be announcing shortly three grant competitions designed to strengthen the linkages between faith-based and community-based organizations and the One-Stop system. The solicitations for grant applications will be published in the Federal Register no later than April.

   With regard to partnerships with faith-based organizations, it should be noted that religious organizations that are receiving WIA funding for social services will not have the benefit of the legal exemption found in other laws (e.g., Title VII of the Civil Rights Act of 1964; the "Charitable Choice" law) to hire on the basis of religion with respect to those funds. This stipulation is not retroactive and applies only to employees hired for the purpose of carrying out the WIA-funded contract with the Local Workforce Investment Board.

5. Action Required. State are requested to:

   1. Encourage Local Workforce Investment Boards to appoint members who are specifically familiar with local grassroots faith-based organizations to work alongside representatives who are familiar with a broad range of other community groups and service providers.
   2. Work with Local Workforce Investment Boards to create campaigns that will educate appropriate local faith-based and community-based organizations about the workforce investment system, including available grants and opportunities for participation and partnership with One-Stop Career Centers.
      1. This can be done through activities such as outreach sessions and networking. Outreach materials designed to educate faith-based and community-based organizations about the workforce investment system are available through the CFBCI website at: www.dol.gov/cfbci. Other outreach support is available by contacting CFBCI at: (202) 693-6450 or at: contact-cfbci@dol.gov.
      2. Education plans should encompass the full scope of faith-based institutions' obligations under section 188 of WIA and its implementing non-discrimination regulations. The education scheme should focus not only on Federal requirements, but make every effort to dispose of the many inaccurate perceptions that exist which prevent greater participation of faith-based organizations in the workforce system.
   3. Ensure that information on State Workforce Agency and Local Workforce Investment Board websites about applying for grants or becoming service providers is easy to find and understand for those non-profit organizations that are seeking to partner with the workforce investment system.

6. Inquiries. Questions or comments can be directed to the Department of Labor's Center for Faith-Based and Community Initiatives at: 202-694-6450 or at: cfbci@dol.gov.