The National Association of RSVP Directors (NARSVPD) appreciates the opportunity to comment on the Proposed Rule (45 CFR Parts 2551, 2552, and 2553 RIN 3045-AA63, Senior Corps: Senior Companions Program, Foster Grandparents Program, and Retired and Senior Volunteer Program. all administered by the Corporation for National and Community Service (CNCS). We will limit out comments to the RSVP Program.
NARSVPD was created in 1976. Its purpose is to provide visibility and advocacy for RSVP; a network of communications among RSVP Directors and projects; a vehicle for expression of majority opinion on behalf of RSVP and older Americans to the CNCS, Congress and other appropriate governmental and national units.
Professional membership is open to all RSVP Directors. Professional members have voting privileges. Associate membership is available to other project staff, sponsors and other interested persons or groups with no voting privileges.
The NARSVPD Board of Directors is composed of nationally elected officers (President, Past President, Vice-President, Secretary, Treasurer) with Delegates and Alternates elected from five Clusters. Professional membership makes eligibility to the Board possible.
NARSVPD, Inc., provides for enhancement of professional development of RSVP Directors through workshops and training programs with technical assistance. Resource development is through networking with both private sector and public agencies.
NARSVPD strives to represent RSVP Directors and to speak on their behalf before national government bodies. The Board works to improve project management through the development of grant opportunities, public/private partnerships, surveys and databases.
We appreciate the Administration’s recognition that RSVP programs will benefit from increased flexibility in program administration while maintaining accountability at the local level and streamline requirements for more effective administration of projects in local communities.
RSVP is the Corporation’s largest program, enrolling approximately a quarter of a million seniors aged 55 and above in volunteer service. RSVP volunteers serve their communities in countless ways because the communities in which they serve have different needs.
Because RSVP is not means-tested and doesn’t remunerate its volunteers it can recruit highly educated specialists in education, health care, law, the environment and other areas, at an average cost of about $200 a volunteer, making it a bargain.
RSVP needs both regulatory and statutory relief. Since 2015, approximately 100 programs with more than 70,000 volunteers have left the program. We believe that these relinquishments are the result of the impact of budget cuts and administrative burdens; some imposed by statute and some by CNCS that have led sponsors to leave the program. While these proposed changes are welcome, we believe that more needs to be done.
In particular, we believe the Corporation should use relinquished funds to strengthen existing programs. We believe that competing relinquished sites will further weaken existing programs while creating a new cohort of under-resourced programs. We are also concerned that a competition that seeks national sponsors will undermine the strong connection that RSVP programs have with the communities they serve and that this competition will reduce the rural footprint by encouraging fewer, larger urban programs that are able to benefit from economies of scale.
We believe that CNCS should analyze why programs relinquish. The answer to that question should lead to a policy of using every available resource to invest in those existing programs that have demonstrated their quality by surviving the competitive process imposed by the Serve America Act, rather than create a larger universe of comparatively under-resourced programs.
We also believe that CNS should embark on a strategic planning process for RSVP and invite public participation to seek input into what RSVP’s mission should be. For example,
· How will CNS develop performance measures that capture both the impact that RSVP has on communities and on the volunteers, themselves?
· How will CNCS capture some share of the 10,000 baby boomers that are retiring every day for the next decade and are an enormous resource?
· What can the Corporation do to accelerate administrative relief, especially to think creatively about using waivers to free programs from an onerous 30 percent matching requirement?
· How will the Corporation address the hollowing out of rural America and the industrial heartland makes it increasingly difficult for programs to find significant local support?
· How will the Corporation fix an administrative structure that allows for which results in programs receiving conflicting messages?
· How can CNCS more aggressively promoted RSVP to other federal agencies as a partner thereby supporting additional RSVP volunteers?
· What research activities are you contemplating that can demonstrate the effectiveness of RSVP in communities and on the volunteers?
· How can CNS improve messaging around RSVP and other senior corps programs?
RSVP is the program in the Corporation’s portfolio that is the purest form of volunteerism. To reiterate, volunteers serve without pay, serving in or supporting local nonprofit organizations and local governments delivering key services. We should be focused on how to maximize RSVP’s potential.
Specifically, with regard to the Proposed Regulations:
1. The summary (page 6740) highlights the emphasis of the updated, proposed regulations: "These amendments will increase flexibility in program administration while maintaining accountability at the local level ...; ... and streamline requirements for more effective administration of projects in local communities." While we support the goal of increased flexibility and streamlining requirements, it isn't clear where that administrative relief and flexibility is described. We are particularly interested in a reassessment of performance measures as they relate to RSVP and the establishment of a clearinghouse or contractor that would remove the burden of background checks from individual programs.
2. Sec. 2553.12 Definitions. Performance measures. Indicators intended to help determine the impact of an RSVP project on the community, including the volunteers. We support the use of performance measures to determine the impact of RSVP on the community, but that is only half the story. CNCS should consider amending the performance mwasur4es to capture the impact of volunteer service on the volunteer.
3. Sec. 2553.12 Volunteer station. - Definition:
We would appreciate it if the Corporation can clarify whether the proposed definition pertains only to proprietary healthcare organizations or other for-profit entities that might serve vulnerable populations. The proposed language states, “Each volunteer station must be licensed or otherwise certified, when required, by the appropriate state or local government.” This appears to require that all stations be licensed. If that is the case, more explicit wording would be helpful.
4. Sec. 2553.22 What are the responsibilities of a sponsor?
CNCS should clarify whether a sponsor may administer more than one Corporation program grant. If the answer is no, will current sponsors who do have more than one grant be grandfathered?
5. Sec. 2553.25 What are a sponsor's Administrative. Responsibilities? (c) CNCS should clarify whether there are any exceptions to the requirement for a full-time project director. Does this apply to apply programs irrespective of size and budget? If there are currently programs that do not have a full-time project director must that program change the nature of the position from part-time to full-time? Or, can the project director be grandfathered? Further: Does the language mean that a sponsor with multiple programs (RSVP and FGP for example) has to employ a full-time project director for each or that there be a full-time project director for Senior Corps projects (s) within its control? What must a sponsor demonstrate in order to negotiate the employment of a part-time project director with CNCS?
6. Sec. 2553.25 (f) Establish Record Keeping and reporting systems NARSVPD has long advocated that CNCS collect only the data it needs and that it use the data it collects.
7. Sec. 2553.25 (h) National Service Criminal History Checks
We again urge the Corporation to contract with a provider to carry out the Criminal History Checks requirements to remove this administrative burden from the individual programs. This would have the effect of making clear who was responsible for conducting such checks and would free valuable time so the programs could address community needs, instead of having to focus on compliance.
8. Sec. 2553.43 (2) Insurance
CNCS should be sensitive to the way that ride share services may be changing the insurance market in cases where state legislation has potential unintended consequences of increased insurance levels and costs for volunteers who use their personal vehicles while volunteering for activities such as Meals on Wheels, transporting clients to medical and social service appointments, etc. Unintended consequences such as these place additional burdens upon volunteers and may make them less likely to volunteer for certain activities that are crucial to rural and large communities with limited public transportation options.
It may be that the proposal that RSVP volunteers who drive their personal vehicles to or on assignments or project related activities maintain personal automobile liability insurance is correct, but this is an area that deserves continued attention.
9. Sec. 2553.71 What is the process for application and award of a grant?
NARSVPD recognizes that competition is a statutory requirement and not something that can be changed through regulation. Nevertheless, we would be remiss if we did express our position that if competition is to remain in effect, CNCS should follow all of the requirements in the Serve America Act that are intended to give programs an opportunity to self-improve, ensure that communities that have RSVP volunteers can continue to benefit from their service, and that the impact of competition on volunteers be minimized, to the extent possible (See relevant section of the Serve America Act below).
''(i)(1) Notwithstanding subsection (g)(3) or section2 412, the Corporation shall continue to fund a program assisted under this section that has failed to meet or exceed the performance measures, outcomes, and other criteria established under this subsection for not more than 12 months if the competitive process established under subsection (e)does not result in a successor grant or contract for such program, in order to minimize the disruption to volunteers and the disruption of services. More broadly, does the proposed Rule affect the statutory language (Section 2143) intended to ''(iv) ensure that- ''(I) the grants or contracts awarded under this section through the competitive process for a grant or contract cycle support an aggregate number of volunteer service years for a given geographic service area that is not less than the aggregate number of volunteer service years supported under this section for such service area for the previous grant or contract cycle; ''(II) the grants or contracts awarded under this section through the competitive process for a grant or contract cycle maintain a similar program distribution, as compared to the program distribution for the previous grant or contract cycle; and "(III) every effort is made to minimize the disruption to volunteers; and ''(v) include the use of performance measures, outcomes, and other criteria established under subsection (g).
10. Section 2553.71, 2(e). Are grants renewable for one three year period or longer?
CNCS should clarify whether grants are renewable for only one three year period, for a total of six, or two three year periods. CNCS should also clarify that programs may remain in the portfolio indefinitely if their performance and compliance with grant terms and conditions are satisfactory.
11. Sec. 2553.101, 102 - Performance measure purpose, application, development of the measures. With such importance given to performance measures, it would be timely and appropriate to reassess and streamline them as well as better acknowledge the
impact of service on volunteers.
We propose that the definition of the purpose of performance measurement should also clearly state that projects can, if they wish, measure/acknowledge the impact on the volunteer.
12. Sec. 2553.103 Who develops the performance measures?
CNCS should clarify whether it is the only entity able to develop performance measures or whether the applicant develops its own specific performance measures? 13. Sec. 2553.108 Failure to the meet target Meet Performance Measure(s)? NARSVPD believes the language in this provision is too harsh. Failure to meet one performance measure should not result in the denial of refunding or termination. The Serve America Act provides that programs that are not performing well should receive Training and Technical Assistance. This provision should be amended to include this option.