State Letter #04-08
Matching Grant Guidelines:
The following constitutes the Guidelines for the CY 2004 Matching Grant program.
- Intake information (date of arrival, number and names of members of the case upon arrival; and, for those in the Matching Grant, documentation showing the individual is eligible for services (see 45 CFR 400.43 and ORR State Letters #00-17, #00-22, #01-13 and #02-01 ), alien number, birth date, current address, health status, educational level, native language, literacy and English language level on arrival, prior work experience and skills, and social security number when obtained);
- Signed and dated Matching Grant enrollment form and letter of Refugee Rights and Responsibilities.
- A resettlement plan (steps and projected time frames to be taken by the refugee, his/her family, and the agency to work toward the earliest possible employment and self-sufficiency for the family including strategies to remove any barriers to self-sufficiency, amount of earnings necessary to be self-sufficient);
- Clear documentation of all services provided to clients based upon the needs and goals identified in the resettlement services plan. If a refugee is enrolled in a training program, the date, type, intended duration, expected outcomes, and provider of the training program also should be indicated in the case file;
- Documentation of regular contact with, and monitoring progress of, adult members of the case over time with summary notes regarding the purpose and outcomes of that contact, coupled with c. above;
- A statement regarding the status of the case at 120 and 180 days after date of eligibility, e.g., whether the employable refugees are employed, number of hours per week, at what wages, place(s) of employment, employer contact information, whether or not health benefits are available within 180 days of placement, self-sufficiency status due to earnings, referred to welfare, etc. This status statement should be located in a designated place in all case files, easily found, and not randomly stated within the case notes.
- Documentation of the provision of childcare and after school care, if any.
- Proposed budget for the respective case with actual expenditures to date. All cash transactions are to be clearly documented and initialed by an adult member of the refugee family. Each file is to have a summary sheet of all cash and in-kind contributions allocable to the Matching Grant program.
- When maintenance support and/or services are extended beyond the minimum 120-day core maintenance period, files should note when the support and/or services are terminated.
- Matching Grant file documentation must be separate from services provided to refugees through other programs and the cooperative agreement. Separation by sectioning Matching Grant from other services in combined files is acceptable.
- Job development: an ongoing process of networking with employers to develop prospective job openings for refugees.
- Job counseling: ongoing interaction between the refugee and the person responsible for job development regarding questions and concerns that refugees have about the world of work, job search, the need for early employment, job retention, and the consequences of refusing an appropriate offer of employment.
- Direct job placement assistance: assisting the refugee to identify and contact prospective places of employment, scheduling appointments for job interviews, preparing refugees for interviews, and following up on results of interviews. Each locale must have a staff person who is responsible for providing or overseeing provision of these services to assist refugees to become employed. This person may receive assistance from sponsors and volunteers in locating employment.
- Follow-up with employer and employed refugees: Contacting the employer (if the agency or the agency's volunteer has found the job placement) and contacting the employed refugees (regardless of whether the agency or the refugee has found the job placement) within two weeks after the refugee has started work to identify any adjustment problems and to assist in the resolution of those problems. Such follow-up activities must occur throughout the first 180 days from date of eligibility. The responsibility for placement and follow-up of Matching Grant refugees resides with the Matching Grant staff. Job developers funded by other sources may share information on job availability with Matching Grant staff and vice versa, but the actual conduct of the above services for Matching Grant clients must be done by the staff of the Matching Grant agency under the Matching Grant funding.
- Services that lead to job upgrades for refugees with particular skills, vocations, or when necessary in order for the refugee family to achieve economic self-sufficiency.
- Subsidized employment may be used to gain entry into the job market; however employment outcomes are only counted when the subsidy ends and the client retains employment; the transition to a non-subsidized job must be completed by the 180th day.
- Plan and coordinate program services with other local service providers in the community. Local Matching Grant affiliates must notify all Matching Grant agencies in the community of enrollment of any Cuban and Haitian entrant, victims of severe forms of trafficking, or asylee that arrives without the benefit of a reception and placement grant to assure non-duplication of enrollment in the Matching Grant program.
- Provide technical assistance and training to local offices regarding the Matching Grant program's administrative, reporting, and other grant requirements.
- Monitor the performance of the grant and subgrant activities and review each program function to assure that adequate progress is being made toward achieving programmatic goals and compliance with Federal grant regulations.
- Monitoring reports, including any corrective actions recommended and follow-up on those recommendations, shall be filed at the grantee's national office.
- Manage grant finances and account for funds according to Federal grant requirements.
- Submit timely programmatic and financial reports and the annual goal plan to ORR.
- Obtain prior approval from ORR before making any significant changes (defined as a 10 percent change, up or down) in the number of clients enrolled in the Matching Grant Program at any given site and before adding any new sites.
- Work with their local affiliates and offices to develop policies in the context of the Federal Food Stamp requirements to assure clients meet the eligibility requirements for the Food Stamp program. [See ORR State Letter 97-28]. ORR recognizes that weekly cash payments may make certain refugee cases ineligible for Food Stamps. Local resettlement agencies may provide some of the weekly allowance in the form of vouchers if such form of payment is in the overall best interest of the refugee and he/she concurs.
- Work with their local affiliates and offices to assure that weekly cash payments are made to the maximum extent possible without rendering the refugee ineligible for Medicaid. Local resettlement agencies may provide some of the weekly allowance in the form of vouchers if such form of payment is in the overall best interest of the refugee and he/she concurs.
- In situations where sanctions are to be applied, procedures must be in place to ensure that clients receive adequate written notice detailing the reasons for the intended action and an opportunity for an adequate hearing before termination of benefits (see Goldberg v. Kelly, 397 U.S. 254 (1970); see, e.g. , 45 CFR 400.54 and 400.82).
- Facilitate the transition to other ORR and mainstream programs at the end of the Matching Grant services.
- English Language Training (ELT)
- Provide or assist refugees to enroll in an English language training class, as needed, according to competency level and previous English language training identified in the resettlement plan. English language training must be concurrent with rather than sequential to employment services. English language training is to be provided without cost to the refugee.
- English language training classes shall be certified or be otherwise taught by trained ELT instructors.
- Classes shall be scheduled so as not to inhibit employment search and employment; i.e., evening classes are recommended where possible. Classes should be geared toward early employment and self-sufficiency to the extent possible.
- Agencies are required to document attendance and progress of the client when ELT is indicated as an essential part of the resettlement plan for employment.
- Grantees shall inform clients that non-participation without good cause in ELT, where ELT is indicated as essential in a resettlement plan for employment, may be considered grounds for sanctioning or termination of maintenance assistance.
- Grantees shall take reasonable measures to ensure that tutoring support services provided by volunteers are coordinated with the English Language Training curriculum and are provided in response to the needs indicated in the resettlement plan. Volunteers should be provided program orientation and ongoing guidance to assist in effective service delivery.
- Health and Medical Services
- Agencies shall assist refugees to access necessary health and medical services including health screenings. These costs are normally covered under Cooperative Agreements. For clients who do not receive such services under a Cooperative Agreement, these costs are allocable to the Matching Grant program.
- Agencies should enroll Matching Grant clients in Medicaid or Refugee Medical Assistance (RMA), and make every effort to ensure that the refugee's need for medical assistance does not result in receipt of public cash assistance.
- Also 45 CFR 400.104(a) states that "[i]f a refugee who is receiving medical assistance receives earnings from employment, the earnings shall not affect the refugee's continued medical assistance eligibility." Section 400.104(b) provides that "[i]f a refugee, who is receiving Medicaid and has been residing in the U.S. less than the time-eligibility period for refugee medical assistance, becomes ineligible for Medicaid because of earnings from employment, the refugee must be transferred to refugee medical assistance without an RMA eligibility determination." Section 400.104 (c) further provides that the refugee shall continue to receive medical assistance until he/she reaches the end of his or her time-eligibility period for refugee medical assistance. Finally, section 400.104(d) provides that "in cases where a refugee is covered by employer-provided health insurance, any payment of RMA for that individual must be reduced by the amount of the third party payment."
- Employment Training or Recertification
- Provide, or assist refugees to enroll in, short-term job training, customized skills training, or job recertification courses, if indicated in the resettlement plan. Such training is allowed if it is expected to lead to self-sufficiency within the first 120-180 days of eligibility.
- Non-Matching Grant funded On-the-Job Training (OJT) may be used only when suitable employment is not obtainable without the OJT or for the purpose of job upgrading. Agencies are expected to find the placement and monitor the refugee's progress. Follow-up on placements continues to be the responsibility of the Matching Grant agency. Job placement is counted from the time the job is no longer subsidized.
- Specialized or customized skill training is an allowable employment service activity where there is a short-term training program available for a refugee with specific skills and for whom the training will lead to self-sufficiency for the case within the first 120-180 days from date of eligibility. Such costs as tuition, books and related support services are allowable and allocable to the Matching Grant program when not otherwise available under other programs. Subsidized employment may be used to gain entry into the job market; however employment outcomes are only counted when the subsidy ends and the client retains employment.
- Social Adjustment Services
- Provide or assist refugees to obtain social adjustment services, such as counseling and interpretation services, when necessary.
- Support Services
- Provide, or assist refugees to obtain childcare (day care and after school care), and address transportation problems that are barriers to self-sufficiency.
- All costs incurred and allocable and services provided in accordance with any Cooperative Agreement may not be charged to the Matching Grant program or counted as a matching contribution.
- All goods and services must be allowable, reasonable and allocable to the Matching Grant, whether paid for by Federal funds or by agency match or in-kind contributions. One guide agencies should use in considering in-kind contributions is whether such goods or services attributed to the match would have been purchased if they had not been contributed.
- Volunteer staff services may be computed using an average hourly rate for all non-professional support or a menu of volunteer rates. Check www.independentsector.org for applicable rates in your community. These rates will then be proposed to the national agencies for review and included in the Matching Grant application. ORR may negotiate rates prior to issuing awards.
- Contributions of goods and services are considered "cash" if the item was paid for. The flow of these donations does not necessarily have to go physically from the donor (i.e., agency) to the donee (i.e., refugee). If the voluntary agency, or the sponsor, pays for the item with non-federal funds and gives it directly to the refugee or the refugee benefits directly from it, it may be considered a cash donation. Such goods and services must be directly related to the self-sufficiency plan of the case and be provided by the local affiliate or sponsor to the client. Incidental goods obtained by the client or activities not related to the Matching Grant program or the self-sufficiency plan (such as trips to the park, movies, etc.) are not allocable.
- When relatives of Matching Grant clients provide housing in their own residence during the match period, this housing cannot be counted as a matching expenditure. However, if the cost for a relative's residence (including utilities) increases as a direct result of housing Matching Grant clients, then only the amount of the increase may be counted as an in-kind match expenditure. Agencies are required to obtain appropriate documentation (i.e., an appropriately dated letter from a landlord documenting the increase and/or a history of utility bills) to verify that an increase in the cost for the relative's housing has taken place as a result of the addition of the Matching Grant client to the housing unit.
- If medical services are performed by private doctors and hospitals claiming reimbursement for such services under Medicaid or Refugee Medical Assistance, additional fees above the Medicaid reimbursement level may not be counted as a matching contribution.
- Staff costs for time spent on services (including the allocable portion of overhead and facilities costs) provided for under the Cooperative Agreement may not be charged to the Matching Grant Program. These costs include staff and volunteer time spent on housing-related matters, medical orientation and referral for initial health screening, assistance in obtaining a social security card, initial intake and development of a resettlement plan, greeting refugees at the airport, and household goods and furniture during the first month. It also includes casework staff costs associated with the requirements of the Cooperative Agreement. Where such services are provided to clients without benefit of the R&P services, such costs are allocable to the Matching Grant program.
- Costs for refugee baggage transfers or shipments are not allowable under this grant.
- Initial health screening referrals and orientation, as described in the Cooperative Agreement, are not considered a Matching Grant activity and thus expenses for such activities are not allowable. Such costs however, are allowable for certain Cuban and Haitian entrants, victims of severe forms of trafficking and asylees who do not receive such services under a Cooperative Agreement.
- Community orientation, as described in the Cooperative Agreement, may not be considered social adjustment services, and is not an allowable activity under the Matching Grant program except for certain Cuban and Haitian entrants, victims of severe forms of trafficking and asylees who do not receive such services under a Cooperative Agreement.
- Elementary, secondary and other school tuition for children is not considered within the scope of the Matching Grant Program and thus is not an allowable service under this section. However, childcare costs and day camps for children of newly employed parents or those in employment-related training are allowable where reasonable and necessary. These costs are allowable for up to 180 days after arrival or until the case accesses public cash assistance, whichever occurs first.
- Due to the Matching Grant's unique statutory requirements, voluntary contributions are not considered program income. Any income directly generated by a Matching Grant-supported activity, however, is to be considered program income. Such program income may be used for allowable costs of the program to meet the Federal match requirements. Program income used as match should be reported on line 10. g of Standard Form 269. For example, if a video is produced using Matching Grant funds and copies are subsequently sold, any profit would be considered program income. (Note: Prior permission from ORR through either the application process or by special request would be needed to produce a video with Matching Grant funds.) Furthermore, if grantees require fees in exchange for the sponsorship of refugees who may be placed in the Matching Grant Program as a condition for the sponsoring of a particular individual, such funds are considered program income and must be reported.
- Grantees must be able to provide at least 33 percent of the total approved cost of the project. The total approved cost of the project is the sum of the ACF share and the non-federal share. The non-Federal share may be met by cash or in-kind contributions, although applicants are encouraged to meet their match through cash contributions. Therefore, a project requesting $200,000 in Federal funds must provide a match of at least $100,000 (33 percent of total approved project costs $300,000.) Grantees will be held accountable for commitments of non-Federal resources even if over the amount of the required match. Failure to provide the amount will result in disallowance of Federal Match.