Definition of Short Term Training
Definition of Short Term Training
September 11, 1981
TO:STATE AGENCIES ADMINISTERING CHILD SUPPORT ENFORCEMENT PLANS UNDER TITLE IV-D OF THE SOCIAL SECURITY ACT, AND OTHER INTERESTED INDIVIDUALS
SUBJECT: Definition of Short Term Training
PURPOSE:The purpose of this Action Transmittal is to provide a definition of the term "short term training" as used in 45 CFR 304.21(a)(2) and 304.23(d).
BACKGROUND:Federal regulations at 45 CFR 304.21(a)(2) provide that Federal financial participation (FFP) at the 75 percent rate is available in the costs of "reasonable and essential short term training of court and law enforcement staff assigned on a full or part-time basis to child support enforcement functions pursuant to the cooperative agreement". In addition, Federal regulations at 45 CFR 304.23(d) provide that FFP is not available under 45 CFR Part 304 for "education and training programs and educational service except direct cost of short term training provided to IV-D agency staff or pursuant to 45 CFR 304.21". Absent a regulatory definition of the term "short term training", in a number of instances OCSE has informally taken the position that this term excludes any training that exceeds 8 weeks in duration, and any training that is part of an educational program leading to a degree.
We have reexamined this position and believe that the definition being used may be too narrow in scope because it could possibly exclude training that would improve an individual's ability to perform his or her current job or other IV-D related jobs. For example, a IV-D investigator may not be familiar with certain current investigative techniques. The IV-D investigator and his supervisor believe that he would be able to improve his ability to locate absent parents by taking a university course in investigative techniques that meets 3 times a week for 12 weeks and will earn the investigator credit hours toward a degree. We believe that this training would benefit the IV-D program and its costs should be eligible for FFP under the program. A secondexample would be a 10 week management seminar that a IV-D worker has been asked to take because he is about to be promoted to a supervisory position. The IV-D workers superiors believe that the seminar will improve the worker's ability to perform his new job. We believe that this training would also benefit the IV-D program and its costs should be eligible for FFP under the program. We want to encourage rather than discourage individuals from taking training that will improve their ability to perform their current jobs or other IV-D related jobs. Therefore, we have developed a definition of the term "short term training" which uses more general criteria than the guideline that has been employed.
DEFINITION:As used in 45 CFR 304.21(a)(2) and 304.23(d), the term "short term training" means any training that would directly improve any individual's ability to perform his or her current job or another IV-D related job, does not provide merely a general education for an individual and is not taken for the sole purpose of earning credit hours toward a degree or certificate.
FFP is available under the above definition regardless of the source of the training. For example, FFP is available for short term training provided by State and local IV-D agencies, or an agency or individual who provides IV-D services under a cooperative or purchase of service agreement. In addition, FFP is available for short term training conducted by the multi-function agency in which the State IV-D agency is located, or by another State or local agency. Short term training provided by a contractor (e.g. college, university, professional association, etc.) is also eligible for FFP at the 75 percent rate.
REFERENCE: 45 CFR 304.21(a)(2) and 304.23(d)
INQUIRIES TO : OCSE Regional Representative
Acting Deputy Director
Office of Child Support Enforcement