County of Residence vs. County of Authorized Position

[mslauren2930]

Q: We have a participant whose county of residence is not one of the counties in which we are eligible to serve participants. However, according to the Data Collection Handbook, "Applicants must reside in the state in which they apply unless the state has an approved cross-border agreement with another grantee, but there is no requirement that applicants reside in the county in which they apply." The participant in question is training in a host agency within one of the counties which we are eligible to serve. Does the issue of county of residence become an issue once someone goes from being an applicant to being a participant?

[charteroakadmin]

A: With the publication of the PY 2012 ED, DOL has announced that compliance with ED will be determined based the county of residence of the participants. County of authorized position is a construct that was created for the 2006 national grantee competition and is not being used at this time. It remains true that the participant need not reside in the county in which she is applying, i.e., the county in which the sub-grantee is located; however, sub-grantees may not enroll participants who reside in counties that the grantee is not authorized to serve. Any current participants who are enrolled with grantees that are not authorized to serve them will be transferred as part of the transition process that is now underway.

Nothing prevents the participant you reference from continuing at her current host agency. The rules require that she be allowed to stay there for at least 90 days after the 10/1/12 transfer, and you can arrange with the recipient grantee for her to remain there after the 90-day "right of first refusal" has expired.