Memo to the Office of Vocational and Adult Education, Department of Education,
Submitted In response to the Request for Information on Strategies for Improving
Outcomes for Disconnected Youth
Submitted by YouthBuild USA, Inc.
Contact: Dorothy Stoneman, CEO and Founder, firstname.lastname@example.org
YouthBuild USA, Inc. was established in 1990 as a national non-profit dedicated to creating
pathways out of poverty for low-income disconnected youth. Its purpose was to demonstrate
continuous success of the YouthBuild program on the ground in an expanding number of urban
and rural communities, and to simultaneously influence public policy toward dramatically increasing
education, employment, service, and leadership opportunities for disconnected youth.
The YouthBuild program itself was started in 1978 in East Harlem as a community-based solution.
It was scaled up by YouthBuild USA, Inc. to 20 communities between 1984 and 1992 with
philanthropic and local public support, and then authorized in public law in 1992 for national
expansion with federal dollars under the jurisdiction of HUD. In 2006 it was transferred to DOL.
YouthBuild USA works as a partner to the federal government in assuring the success of the
YouthBuild program. It serves as contractor to DOL (selected through a competitive process)
providing training and TA to DOL’s YouthBuild grantees; and it brings catalytic public and private
dollars into the system for innovation and program enhancements that, once tested, are integrated
by DOL into its delivery system.
We are pleased to be able to respond to the RFI with some of the lessons that we have learned
from working with seven federal agencies and local YouthBuild programs operating in 273 urban
and rural low-income communities across 45 states, serving 110,000 disconnected youth to date.
Below are our responses to the specific questions asked in the RFI.
I. Effective or Promising Programs and Strategies
1. What Federal, State, and local programs or community collaborative efforts have
improved outcomes for disconnected youth? What is the objective evidence of their
success (e.g., evidence from rigorous evaluations using, for instance, random assignment
and regression discontinuity design)?
From our observations, the programs that are most effective for disconnected youth are the full-
time community-based programs that combine education, job training, and community service, and
provide stipends, living allowances and/or education awards. These include AmeriCorps, Service
and Conservation Corps, and YouthBuild. While AmeriCorps has not been focused on
disconnected youth, its usefulness for this population has been demonstrated and it could be
expanded, as recommended by the White House Council on Community Solutions.
Most of our discussion will be focused on YouthBuild, because it reflects our greatest expertise.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 1
The YouthBuild program has been proven effective for improving outcomes for the most
disadvantaged disconnected youth. YouthBuild is a comprehensive community-based program
started in East Harlem in 1978 and scaled up since then through public-private partnerships to 273
urban and rural communities in 45 states. Its delivery system integrates funding from local, state,
and federal public entities, and generates innovation with the help of private corporations and
YouthBuild’s philosophy is based on combining the power of love and the power of opportunity in a
well codified and comprehensive program design. Participants enroll full-time for 6 to 24 months,
with time equally divided between highly individualized classroom education toward a GED or
diploma, and hands-on training building affordable housing for homeless and low-income people in
their neighborhoods. Additional vocational training tracks in healthcare, technology, and other
areas that serve the community have been added by some local programs and approved by DOL.
YouthBuild is knit together with personal counseling, leadership development, positive peer group
development, and community service.
The foundation of the YouthBuild delivery system is the US Department of Labor’s YouthBuild
program, authorized under the Workforce Investment Act and managed by the Employment
Training Administration. DOL contracts with YouthBuild USA (selected through a competitive
process) to provide training, TA, and data management to DOL’s grantees who are local non-profit
or public entities selected by DOL through a competitive process to run a local YouthBuild
program. Each grantee must provide 25% non-federal match; this requirement incentivizes local
YouthBuild USA complements DOL’s management role by independently bringing in funding from
other federal agencies and from private philanthropy for innovation and growth that integrates the
purposes of these other entities. When these prove successful, DOL integrates the innovations
into the basic system. YouthBuild USA also uses private funds to build leadership opportunities for
staff and young people. This is a robust delivery system that combines federal, state, local, private,
and non-profit resources; engages directors and youth in leadership roles affecting program policy
and design; and combines central accountability with local community-based leadership and
collaborative program development.
The objective evidence of its success includes: A) Positive outcomes and resulting return on
investment over time; B) Many independent qualitative and quantitative research studies
demonstrating YouthBuild’s effectiveness and cost efficiency; and C) Enormous demand from local
communities expressed through high levels of application.
A. Positive Outcomes and Return on Investment
Consistent outcome reports managed by YouthBuild USA over two decades show that roughly half
of YouthBuild enrollees succeed in changing the course of their lives during the program period by
obtaining a GED or diploma and/or getting placed in a job and/or post-secondary education.
Given the ROI estimates developed by Belfield et al at Columbia University in “The Economic
Value of Opportunity Youth” showing a lifetime taxpayer burden of $236,000 for each 20 year old
disconnected youth and a lifetime social burden of $704,000, and the over-all $1.2B federal
investment in YouthBuild for 110,000 disconnected youth since 1994, this represents an estimated
total savings of taxpayer burden of $11.6B and savings of social burden of $34B. This is based on
conservatively assuming the successful lifetime reconnection of 45% (50,000) of YouthBuild
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students. This does not attempt to assess the gains made by students who did not succeed in a
measurable way during the program period but made gains later as a result of the program. Nor
does it estimate the value to family members and neighbors of successful graduates, nor the value
of the housing they produced.
Independent research by Mark Cohen of Vanderbilt University found that the minimum lifetime
return on investment for every dollar spent on a YouthBuild student was $7.80, based on the
educational gains made; and the ROI per dollar spend on court-involved students ranged from
$11.90 to $43.80.
Demographic and outcome data collected by YouthBuild USA from 131 programs in 2010 show
that one hundred percent of YouthBuild enrollees are low-income; 94% lack a high school diploma;
71% are young men and 29% young women; 32% are court involved, 15% convicted of felonies;
10% in foster care; 54% African American, 22% White, 20% Latino, 4% Native American, 3%
Asian American; average reading grade level at entry is 7.2. An average of 78% of enrollees
completed the program. 51% obtained their GED or high school diploma during the program
period. 63% of completers were placed in college and/or in jobs with an average wage of
$9.20/hour. Over many years in various studies, recidivism rates have ranged from 5 – 28%
compared to a national rate of 67%. There are 2 to 10 times as many applicants as can be
accepted at each program.
B. Many Research Studies
Research conducted on YouthBuild since 1996 are listed below. Some were contracted and
funded by government agencies; some by YouthBuild USA with private funds; some by other
entities or individual researchers with their own funds. They are listed in reverse chronological
Peter Levine, PhD, CIRCLE, Tufts University. Pathways into Leadership; A Study of
YouthBuild Graduates. 2012. (Funded by Knight Foundation)
Mark Cohen, PhD., Alex Piquero, PhD: Costs and Benefits of a Targeted Intervention
Program for Youthful Offenders: The YouthBuild USA Offender Project, 2008.
(Funded by YouthBuild USA.)
Social Policy Research Associates: The YouthBuild Program for Ex-Offenders, A
comprehensive Qualitative Review 2008, contracted by the US Department of Labor.
Anne Leslie, YouthBuild USA Youthful Offender Project, Year 1, YouthBuild USA, 2007.
Leslie Crutchfield and Heather McLeod Grant, Duke University’s Center for the
Advancement of Social Entrepreneurship: Fast Growth High Impact Nonprofits
Research Overview. 2007.
Andy Hahn, Heller School, and Tom Leavitt of Analytic Resources: The Efficacy of
Education Awards in YouthBuild AmeriCorps Programs: A Report for the Corporation
for National and Community Service, 2007.
Report to Congressional committees, GAO-07-82 US GAO, February 2007; William B.
Shear. YouthBuild Program.
The Bridgespan Group. YouthBuild USA: Achieving Significant Scale While Guiding a
National Movement. The Bridgespan Group, Inc., 2004.
Center for the Advancement of Social Entrepreneurship. Greg Dees. The Growth of
YouthBuild: A Case Study. Fuqua School of Business, Duke University, 2004.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 3
Hahn, Andrew, Leavitt, Thomas D., Horvat, Erin M., Davis, James E. Life After
YouthBuild: 900 YouthBuild Graduates Reflect on Their Lives, Dreams, and
Experiences. Brandeis University, Temple University, 2004.
Minnesota Department of Employment and Economic Development: Minnesota
YouthBuild Program: A Measurement of Costs and Benefits to the State of
Perkins, Jr., Jeffrey. The Evolution of YouthBuild USA: A Case Study of
Organizational Innovation and Growth in a Changing Social Policy Environment.
University of Pittsburgh, 2002. (PhD thesis).
Anne Wright, The YouthBuild Welfare-to-Work Program: Its Outcomes and Policy
Implications. YouthBuild USA 2001.
Ferguson, Ronald F., Clay, Philip L., Snipes, Jason C., and Roaf, Phoebe. YouthBuild in
Developmental Perspective: A Formative Evaluation of the YouthBuild
Demonstration Project. Harvard University, Massachusetts Institute of Technology, and
Public/Private Ventures, 1996. (Funded by the Ford Foundation).
Synopses of Key Research on YouthBuild
i. Cost-Benefit Studies:
Mark Cohen PhD, and Alex Piquero, PhD, Costs and Benefits of a Targeted Intervention Program
for Youthful Offenders: The YouthBuild USA Offender Project (2008). This is a cost-benefit analysis
of YouthBuild USA’s targeted intervention program aimed at youthful offenders using data on 388
offenders at 34 local programs. The authors found (1) evidence of reduced recidivism and
improved education outcomes, and (2) a positive benefit-to-cost ratio, with every dollar spent on
every youth estimated to produce a social return on investment of at least $7.80 for the education
gains; and every dollar on court-involved youth estimated to produce a social return on investment
between $10.80 and $42.90, with benefits to society ranging between $134,000 and $536,000 per
participant at a cost to society of about $12,500 (training stipends to students are excluded from
this $12,500 because they were connected to producing affordable housing.)
Minnesota Department of Employment and Economic Development, Minnesota YouthBuild
Program: A Measurement of Costs and Benefits to the State of Minnesota, revised 2003. This
study measures the benefits of increased earnings, state taxes paid by participants on these
earnings, and reduced state prison costs of participants with a prior offense. It focuses on the
YouthBuild programs funded by the State of Minnesota. The study finds that each new group of
youth trained in the Minnesota YouthBuild program produces approximately $350,000 per year in
additional state tax revenues and $1.2 million in state prison cost savings in the first year after
finishing the program. This translates into approximately $1.5 million in direct benefits in the first
year after a participant cohort exits the program, compared to the state’s cost of $877,000 per year.
ii. Qualitative Studies:
Ronald F. Ferguson et al., YouthBuild in development perspective: A formative evaluation of the
YouthBuild demonstration. Department of Urban Studies and Planning, Massachusetts Institute of
Technology, 1996. This study, a qualitative and quantitative analysis, examined the first five
demonstration sites for two full cycles. It included pre and post interviews of over 60 students.
Comparison with other nationally known youth programs showed that YouthBuild had the highest
level of GED achievement. The study defined the observable stages of personal development that
students went through to change their identity and relationship to society. It also defined the key
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elements of the top performing sites correlated with high outcomes. These elements included:
1) attention and support from the sponsoring agency; 2) excellent leadership at the program level;
3) fidelity to the YouthBuild philosophy and program design; 4) sufficient flexible funding to address
issues as they arose without bureaucratic obstacles; 5) control by the sponsoring organization over
the construction sites and housing development; 6) excellent training and technical assistance; and
7) a cohesive, caring, and competent staff.
Anne Wright, The YouthBuild Welfare-to-Work Program: Its Outcomes and Policy Implications.
YouthBuild USA, 2001. This is a study of a three-year grant funded by DOL run from 1998 to 2001
by YouthBuild USA at ten programs. The outcomes of the YouthBuild Welfare-to-Work (WtW)
program were higher than those of other WtW programs recruiting under the same eligibility
regulations, with 50 percent of all trainees being placed in a job at the end of the program,
compared to 44 percent of other WtW program enrollees. YouthBuild graduates earned an average
of $7.91 an hour in their first job placement (in 2001), compared to $6.81 an hour for other WtW
Life After YouthBuild: 900 YouthBuild Graduates Reflect on Their Lives, Dreams, and Experiences.
Heller School at Brandeis University (Andrew Hahn, Thomas D. Leavitt) 2004. This study
combined a 15-page survey of 900 graduates from over 30 programs and in-depth interviews with
a cross-section of 57 randomly selected graduates at eight programs. Both the survey and the
interview results showed that YouthBuild graduates are highly positive about their program
experiences, appreciating both the family-like environment and the high expectations of the staff.
The survey results showed that 75 percent of these graduates were either in postsecondary
education or in jobs averaging $10 an hour; 91% of graduates rated their YouthBuild experience
highly; 85% were still involved in community activities; and a high percentage were successful and
free of government supports using a variety of indicators. Many graduates also felt a need for
more assistance with personal or career-related issues after graduation.
Evaluation of the YouthBuild Youth Offender Grants. Social Policy Research Associates, 2009. In
2004, DOL selected YouthBuild USA to participate in its Incarcerated Youth Offender Program,
granting $18.2 million over three years to YouthBuild USA for 34 local YouthBuild programs
enrolling over 1200 youth. Outcomes exceeded all but one of the short-term targets, including
enrollment, completion, GED/HSD attainment, placement, wages, and recidivism.
DOL engaged Social Policy Research Associates (SPRA) to do a thorough qualitative study of the
program in its third year. The evaluation assessed recruitment and enrollment, educational
services, vocational training, case management and retention, and youth leadership and
The study found that all the programs adhered to the basic YouthBuild program design and
philosophy, and beyond that the higher performing programs shared certain characteristics: they
were usually part of a larger sponsoring agency in which leadership treated YouthBuild as a
priority, had a lower student-to-staff ratio, offered their GED preparation or high school classes
onsite with teachers from similar backgrounds as the students, effectively linked vocational training
to academic instruction, offered industry recognized certifications, had a youth policy council to
advise the director, and offered both housing rehabilitation and new construction. It found that the
intensity of partnerships with other local agencies did not correlate with higher outcomes. It was
more important to have a cohesive internal program community.
The Efficacy of Education Awards in YouthBuild AmeriCorps Programs: Center for Youth and
Communities, Heller School for Social Policy and Management, Brandeis University, Andy Hahn
and Tom Leavitt, 2007. This report looks at the degree to which AmeriCorps Education Awards
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affect involvement in postsecondary education-related activities, utilizing comparisons between
YouthBuild AmeriCorps and other YouthBuild completers. The analysis showed that (1) program
completers at YouthBuild AmeriCorps programs were more likely than completers at non-
AmeriCorps YouthBuild programs to have applied to and been accepted to postsecondary
education or training institutions, and to be preparing for a variety of postsecondary educational
options, and (2) within the YouthBuild AmeriCorps respondent population, those who actually
earned an AmeriCorps Education Award were more likely to apply to, be accepted to, and be
enrolled in post-secondary institutions than those who did not earn an AmeriCorps Education
Award. Effects were particularly strong among black men.
Pathways into Leadership: A Study of YouthBuild Graduates, CIRCLE, Tufts University, Peter
Levine, 2012. This report studied YouthBuild students who had participated in YouthBuild USA’s
pathways into civic leadership and found them to be extraordinarily effective. Young people who
faced enormous challenges at entry to YouthBuild and barely expected to live to age 25 changed
their trajectory, internalized the skills and values to become committed civic leaders, with many
becoming non-profit professionals, pastors, and even elected officials.
C. Enormous Demand from local Communities and Young People
Over 1,600 distinct community-based public or non-profit organizations applied to HUD for
YouthBuild funds between 1996 and 2006 (when it was authorized under HUD, before being
transferred to DOL in 2006). Since 2006 several hundred organizations have applied annually to
DOL to bring YouthBuild to their communities.
We estimate that even if only half of these organizational applicants have the capacity to run a
good program, there is both capacity and will to bring YouthBuild to at least 800 low-income
communities. Current federal investment only supports YouthBuild in about 160 communities.
At existing YouthBuild programs between two and ten times more young people apply as can be
accepted (except in rural communities where dispersed population creates less demand). The
same young people who are leaving high school without a diploma are lining up outside
YouthBuild. In some communities the demand is overwhelming: e,g, in Providence, RI, YouthBuild
has 900 applicants for 50 slots; YouthBuild Philadelphia has 1,000 applicants for 200 slots. If the
young people had vouchers, YouthBuild would expand exponentially based simply on market
2. What program designs have great promise of improving educational, employment, or
other key outcomes for disconnected youth? What is the best evidence to support these
program designs (e.g. correlational or longitudinal outcomes analyses)?
YouthBuild focuses on disconnected youth growing up in low-income communities. Their
prospects and needs are different from those of youth from middle class or wealthy families who
are out of school and out of work. The recent reports showing 6.7 million disconnected
“opportunity youth” (called such because they both seek opportunity and offer opportunity to the
nation if it would invest in them) are not limited to youth from low-income families and communities.
What follows is the program design that we have found to be a “formula to flip the script” of the
lives of low-income disconnected youth.
Low-income disconnected young people seize the opportunity to transform their lives and achieve
their goals when they are offered in one coordinated package the combination of program
elements that they need in order to flourish, which should include all of the following:
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A way to resume their education toward a GED or high school diploma
Skills training and certifications toward decent-paying, family supporting jobs
An immediate, visible role contributing to the community that gains them respect from
family, neighbors and adults generally, as well as self-respect and pride in making a
difference for others
Stipends or wages in return for what they produce in order to sustain themselves and their
Caring personal counseling and mentoring from admired and deeply responsive adult role
models, some of whom have the same background as the young people, who are
committed to their success, who also firmly challenge self-defeating behavior and attitudes
Positive peer support with an explicit value system strong enough to compete with the
A mini-community to belong to that is safe, stands for something they can believe in, and in
which everyone is committed to everyone else's success
A role in governance, participating in making important decisions regarding staff and
policies in their own program
Leadership development and civic education that provide a vision of how they can play an
important role in the neighborhood and society by changing the conditions that have
harmed themselves and the people they love, and that gives them the skills to do so
Assistance in managing money and building assets, as in scholarships, and personal
Linkages and placements with colleges and employers
Support after graduation to succeed in these placements and as a member of a supportive
Young people need to experience a loving and lasting commitment to their personal well-being so
that they can find the confidence and motivation to define their aspirations and gain the skills to
take steps toward their goals. Most low-income high school dropouts say that they left the public
school because nobody cared about them enough to make sure they learned, to help them
overcome personal challenges, or sometimes even to learn their names. In re-engagement
programs, they must feel that the staff care about them more than they ever expected, and in ways
beyond a basic job description. This is the primary element for success.
All program elements need to be implemented with profound respect for the intelligence and value
of the young people and their culture. Programs that are successful in recruiting and graduating
young black men, for example, tend to have caring older black men on staff, attract enough young
men so they are not in a small minority, and can experience the program as one where they
belong, and where their culture is honored.
The most successful programs build a mini-community of people committed to each other’s
success, provide technical skills and personal supports, opportunities to grow and achieve,
sanctions against negative and self-destructive behavior, and a clear path to a productive future,
within a positive and explicit set of values. This is what any healthy community does for its
members. In YouthBuild programs, an explicit set of values is communicated through a program
pledge that youth write and then recite daily.
Any program that can offer this comprehensive combination will work for most disengaged young
people. Each element is important. When it comes in one package the young people will say, "I
was looking for a job or a GED, or a way off the streets, or a way to meet the requirements of my
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probation….and what I found was a family. I don’t know why they cared about me so much, but
they did. It changed my life."
It is important to think in terms of opportunities rather than services, with each participant an active
agent who must seize the opportunities offered, not a passive recipient on whom services are
bestowed. It is also important to integrate the opportunities into a cohesive community, avoiding
fragmentation of delivery in a variety of settings that do not share a common culture. Please note
that the qualitative research done on YouthBuild by Social Policy Research Associates found that
the level of collaboration with other partners was less correlated with success than the level of
internal cohesion of the program community created.
Supportive evidence of the efficacy of this set of design elements is included in our answer to
question #1, above.
3. What discrete interventions, strategies, or practices would need to be included in pilot
designs or innovative programs to increase the likelihood of their success, particularly
This question is addressed in our answer to question #2, above.
4. What are the best ways to involve youth in planning and implementation in order to help
ensure that projects will be effective in meeting their needs?
We believe that any entity that is focused on programming for teenagers or young adults should
engage a representative group in providing input on planning, program design, policy, and
implementation, and this group should meet regularly with the highest executive in the entity.
The engagement of young people in decision-making is an opportunity for their leadership
development and also for the improvement of programs at every level. All schools and youth
programs would be vastly improved if young people—their primary constituents—were actively
engaged in decisions affecting policy, personnel, and program. Not only do they provide accurate
feedback on what is needed and what is going on, but they are inspired by being treated with so
much respect and this motivates them to succeed.
Three important practices that maximize leadership development are as follows:
Embedding the attitude and practice of youth leadership development across all aspects of
the program, in every component
Creating, training, and sustaining a youth policy committee involved in program governance
that meets on a weekly basis with a director who respects the input of young people
Developing and using a set of leadership competencies to track and measure skill
A. Leadership Development in all aspects of a program
Leadership and youth engagement in decision-making works best if leadership activities,
training, roles, and expectations are built into all components of the program. In the classroom,
students teach other students, help determine curricula, debate issues, develop critical thinking,
and evaluate teachers. On the worksite, young people rotate through jobs like foreman, tool
chief, safety captain. In the counseling and life skills areas, they are taught peer counseling,
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mediation, restorative justice practices, community mapping. In program operations, young
people accompany the director on fundraising visits, speak to visitors or the media, lead
morning meetings and community events, care for the physical environment, care for
equipment, and learn leadership skills in myriad other ways.
B. Youth Policy Committee:
In well-functioning YouthBuild programs there is a Youth Policy Committee, composed of 6-10
young people, elected by their peers, who meet weekly with the director about program issues. It is
important that this committee meet with the director, not staff with lesser authority. The
responsibilities generally include interviewing and participating in staff hiring, and consulting on all
important programmatic issues and policies.
There are many potential benefits of having young people involved in this key decision-making
committee. The policy committee can
• Present good solutions to pressing problems, truly aiding the director
• Set a positive tone for the entire program
• Make the program more responsive to the needs and successes of the young people and
thereby increase outcomes
• Allow members to learn how an organization works
• Be the training ground for young leaders who can take what they learn on the policy
committee and apply it out in the world.
• Help young people learn leadership skills sought by employers and colleges
C. Leadership Competencies.
The third key Leadership Development practice is the use of a set of Leadership Competencies.
Leadership competencies are the kinds of foundational skills sought by employers and needed to
succeed in higher education.
YouthBuild USA has developed a set of 23 Leadership Competencies that cover personal
responsibility, small group leadership, and community leadership. Each competency has an
example of a benchmark to assess achievement of the competency. Activities across the program
provide opportunities for participants to work toward competency attainment. Programs set
standards for completion of a leadership skills certificate which can be added to the student’s
resume or portfolio.
II. RFI: Public and Private Partnerships
1. Which State, local, non-profit, and business partners have been involved in the
successful initiative(s) addressing the needs of disconnected youth that you may have
described in response to one or more of the questions in this RFI? Which partners should
be involved in the future?
State funding partners for aspects of YouthBuild programs have included State Commissions on
National Service, Offices of the Attorney General, State Departments of Education, Corrections,
Labor, Governors’ offices, and legislatures.
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Departments of Education have provided charters for YouthBuild charter schools that enable local
programs to enroll many more students than the federal DOL funding alone would allow and
enable the achievement of a diploma rather than a GED.
All of these entities should be involved in every state. Getting disconnected youth back on track to
productive, crime-free, responsible lives that enhance their own and their children’s education,
build careers in high demand industries, and internalize the ethic of service is among the missions
of all these entities.
Unfortunately no state or local entity is typically assigned responsibility for disconnected youth.
Each governor should create a cross-agency council to address the needs of disconnected youth,
assign a commissioner, and set objectives for reconnection through all available pathways, using
federal, state, and local resources.
Several outstanding examples of effective coordination that have specifically affected YouthBuild at
the state level follow. Each of these was created by a State YouthBuild Coalition in partnership
with state government.
In New Jersey the Office of the Attorney General (OAG) worked with the Governor’s office to direct
discretionary funds to expand funding for existing YouthBuild programs and to fund additional
programs in high-need neighborhoods. The OAG issued an RFP that precisely replicated the
federal RFP, so there would be no bureaucratic complications or regulatory confusion. It issued an
additional $250,000 to each DOL YouthBuild grantee and funded three new programs under the
same guidelines, positioning them to compete in future DOL competitions. The OAG had selected
YouthBuild as the most outstanding crime prevention initiative that would save the state money.
This was initiated under Governor Corzine (D) and continued under Governor Christie (R).
In Massachusetts the State legislature has worked with the Governor’s office to support a line item
that would fund all existing YouthBuild programs in the state. Each year since 1996 the legislature
has provided core funding of approximately $200,000 for each of eleven local YouthBuild programs
through the state Department of Education under guidelines identical to those of the federal
program. No regulatory confusion or inefficiency has been created.
In Minnesota the legislature passed a bill similar to the one authorizing the federal YouthBuild
program and for over 20 years the state has appropriated approximately $50,000/year for each
YouthBuild program. Through independent research Minnesota found that its investment
generated nearly $2 in savings for each dollar spent within one year after graduation of each
In Wisconsin, the Governors’ Office established a funding stream through the criminal justice
system that reimbursed each YouthBuild Fresh Start program $10/hour for each student referred
through the criminal justice system.
Local public entities that have frequently partnered with YouthBuild programs include local WIB’s,
One-Stop Centers, community colleges, Mayors’ offices, housing authorities, public school
systems, probation and parole offices, and county jails. These partnerships have taken various
forms based on the local relationship and negotiations: funding, referrals, in-kind contribution of
services or staff, facilitated entrance of YouthBuild graduates, shared physical space. Sometimes
the local entities have actually sponsored the YouthBuild program directly, because public entities
are eligible to apply for YouthBuild funds. WIB’s, community colleges, and housing authorities
have been the most frequent public sponsoring entities.
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Individual YouthBuild programs have also developed close working relationships with local non-
profit groups. Rather than reinventing wheels, by tapping into existing non-profit resources local
programs have increased their counseling capacities, implemented mentoring programs,
developed housing resources for participants, instituted tutoring initiatives, accessed child care for
students’ children, and installed a wide range of other program supports that complement their core
programming. Such private collaborations leverage public resources and strengthen communities’
social service safety net.
Again, the fact that local YouthBuild programs are sponsored by existing community-based
organizations who apply for federal YouthBuild funds means that the strongest existing local non-
profits play the key role. Local affiliates of well-known national organizations often sponsor and
manage the local YouthBuild: e.g. the local United Way, YMCA, YWCA, Urban League,
Conservation Corps, or Community Action Agency.
Many of the local sponsoring agencies for YouthBuild programs would be excellent lead agencies
for collaborative local approaches to integrating resources across agencies for reconnecting youth.
Hopefully the Performance Pilot model will allow for the possibility that a local CBO could be the
Business support to the YouthBuild network has been provided primarily by the philanthropic arms
of large corporations such as Home Depot, Bank of America, JP Morgan Chase, Walmart, State
Street Bank, and Saint Gobain. Generally they have made grants to YouthBuild USA, who re-
grants to selected local programs that meet the geographical or programmatic priorities of the
business. YouthBuild USA takes responsibility for quality, reporting, and communications about
the investment. This creates an innovative cutting edge in the delivery system.
2. What role did or what role could philanthropic organizations play in supporting these
types of initiatives you may have described in response to one or more of the questions in
From its inauguration in 1978, private philanthropy has played a critical role in the development of
the YouthBuild network. At every point, private philanthropies and corporate foundations have
invested in program development, expansion, evaluation, innovation, and capacity-building
managed by YouthBuild USA at the national level, and used to enhance local programs through
pilot demonstrations. These pilot demonstrations then serve to inform program design in the
federal YouthBuild program, and best practices are spread throughout the federal network by
YouthBuild USA as DOL’s TA provider, with the approval of DOL, once they are proven to work at
the local level. This is a uniquely successful delivery system, combining the power of the federal
government with the flexibility of private philanthropy coordinated by a national non-profit.
YouthBuild USA has succeeded in complementing total federal YouthBuild appropriations of $1.2B
with national private investments of over $100M that enhanced program quality and flexibility.
Several such innovations supported by private funds are described below.
A) Post-Secondary Access and Completion
YouthBuild USA makes supplementary grants to DOL-funded YouthBuild programs to implement
pathways into and through postsecondary degree and credential programs. This work leverages
DOL’s investment and has been funded by a mix of private and public funders, including the Bill &
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 11
Melinda Gates Foundation, the Open Society Foundations, and the Corporation for National and
Community Service (via the Social Innovation Fund and New Profit Inc).
With this support, entrepreneurial leaders of 26 YouthBuild programs are strengthening
partnerships with postsecondary institutions, improving academic offerings, deepening graduate
supports and dramatically increasing the numbers of YouthBuild graduates who complete
postsecondary credentials on their way toward building family sustaining careers and
demonstrating leadership within their communities.
Aggregate Results for YouthBuild Programs Participating In Post-secondary Pilot
2007-2008 2008-2009 2009-2010 2010-2011
School Year School Year School Year School Year
(Baseline (Year One of (Year Two of (Year Three of
Before PSE) Initiative) Initiative) Initiative)
GED/HSD 51% 57% 71% 74%
Postsecondary 20% 29% 38% 42%
(Enrolled and in
Postsecondary NA NA 59% 46%
Retention Rate (completers (completers or
(Enrolled in enrolled through enrolled through
Subsequent first year of second year of
Year(s) of Study) postsecondary) postsecondary)
This project demonstrates that high-performing community based organizations can inform and
improve secondary and postsecondary education systems. Student-centered instruction,
hands-on learning, proactive student support systems, meaningful relationships and extensive
focus on service and leadership development must become consistent and essential principles
and practices for improving postsecondary access, retention, and completion strategies.
By maintaining an explicit and sustained focus on enriched instruction aligned with college and
career readiness standards, YouthBuild principals and classroom instructors have increased
graduation rates and prepared more young people to leave YouthBuild ready for credit-bearing
work at the postsecondary level. Instructional leaders have extended learning time, aligned
curriculum and pedagogy with college courses, focused more on balanced literacy and
foundational numeracy, and implemented more student-centered instruction.
The partnerships have been strengthened and improved by formal agreement structures and
commitments. Each site has established at least one formalized agreement structure (i.e.
memorandum of understanding, data sharing agreement, articulation agreement) with its
respective postsecondary partner. Formal agreements have included a broad range of
respective roles and responsibilities related to data sharing, dual credit opportunities, transition
and student support services, access to facilities and resources, and shared staffing models.
Most sites have also negotiated agreements for cohort-based services to groups of YouthBuild
graduates transitioning to and through degree/credential programs.
The strongest partnerships have expanded to include working relationships with campus
presidents, deans of instruction, deans of student development, department chairs, career and
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 12
guidance instructors, writing instructors, math instructors, bridge program coordinators and
adjunct faculty members.
B. Development of a Health Care Career Track
The Walmart Foundation made substantial grants to YouthBuild USA for the development of a
health care career track. This resulted in 15 programs testing this approach, and the development
of a Handbook for programs that wanted to replicate it. Partly as a result of this demonstration, in
2011 the DOL changed the regulations for YouthBuild grantees to include health care, technology,
and other career tracks that would include service to the community.
C. Access to Registered Apprenticeships
The C.S. Mott Foundation made grants to YouthBuild USA to support career development activities
through which YouthBuild USA developed close working relationships with the national AFL-CIO
and through them with local Building Trades Councils to facilitate the use of the Multi-Craft Core
Curriculum that the Building Trades has developed. This partnership facilitated the creation by
DOL of a working committee including DOL, YouthBuild USA, AFL-CIO, other unions, and HUD to
maximize access to registered apprenticeships.
D. Transition to Green Building
Bank of America, Saint Gobain, State Street Bank, and Walmart all made grants to YouthBuild
USA to strengthen green building capacity at local YouthBuild programs and to develop green
training capacity at YouthBuild USA. Soon thereafter, DOL provided additional green grants to
local programs and strengthened its expectations for green building by local programs.
Over-all Partnership between DOL and YouthBuild USA
The over-all partnership between DOL and YouthBuild USA in delivering quality programming that
generates innovation at the level described above may be unusual. On the one hand, DOL
operates the federal YouthBuild program free of control from YouthBuild USA. On the other hand,
YouthBuild USA implements private philanthropic program enhancements free of control from
DOL. Both DOL and YouthBuild USA deliberately complement each other’s work. DOL integrates
successful innovations into the federal program. The resulting synergy is excellent.
YouthBuild USA also plays the role of positioning local YouthBuild programs to assist other federal
agencies in achieving their goals, and integrating funding from different funding streams into one
comprehensive program in the local community. Grants that pass through YouthBuild USA as an
intermediary from CNCS, HHS, DoEnergy, USDA, and OJJDP bring specific program
enhancements to the local level and leverage the DOL YouthBuild program for achieving goals in
community service, disaster relief, IDA creation, weatherization of affordable housing, rural
community development, and mentoring for youthful offenders.
There are other examples of the key role national non-profits play in enhancing quality and delivery
of federal programs across state lines. The AmeriCorps national direct delivery system is a superb
example of how CNCS has leveraged the power and dedication to quality offered by national non-
profits that deliver defined program models in many states. These national non-profits, such as
Teach for America, City Year, Public Allies, The Corps Network, Habitat for Humanity, all
coordinate private funding with public AmeriCorps funding in a way similar to what YouthBuild USA
does for DOL’s YouthBuild program.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 13
When thinking about the role of private philanthropy, we believe it is very risky to put too much
pressure on private foundations to match public investment, because the public regulations then
extend to what has historically been an unencumbered force for innovation and creativity.
Philanthropists should get to exercise flexible judgment about what innovations under what
leadership are worthy of their catalytic investment. This resource should remain a powerful
independent force for good. The federal government should not create initiatives that require large
private match requirements, sopping up the available resources for flexible innovation.
3. How were the partnerships involved in those initiatives structured (e.g., governance
models, provision of services, shared funding, collaborative professional development)?
The above initiatives include several types of partnership:
A. Independent, synergistic partnerships between federal agency and national non-profit
Private funds were raised by the national non-profit to create enhancements to the federal funding
stream, either in program design, evaluation, local capacity, or new frontiers of program
development. The government had no control over these, and did not require them. The national
non-profit shared the results with the government so the government could choose to integrate
them into the federal program.
This model depends on the existence of a healthy national non-profit dedicated to the success of
the federal program, and a positive relationship between the federal entity and the non-profit. This
may exist in many cases, but it has not been understood or featured in studies or policy. A study of
Independent, synergistic national partnerships should be done.
B. Subordinate, Contractual Relationships
A public agency contracts on a competitive basis with a non-profit to provide specific services
toward assuring quality program delivery. This is a well-tested system. Its success varies based
on the quality of both the non-profit and federal management, the quality of services provided, and
the respect between the parties.
C. Subordinate Match Relationships
A public funder requires a level of private match which the grantee must raise, and the match must
follow the regulations of the public funder. While this limits the cost to the public entity, it limits the
freedom of the private funder and program deliverer. For example, in YouthBuild programs each
local program must raise a non-federal 25% match. However, because the federal guidelines
prevent the spending of federal money on food for the participants, the match also cannot be used
for this purpose even though the need is intense. The local non-profit has limited fundraising
capacity, so its priority is to meet the match. As a result, feeding the hungry students may take a
back seat, negatively affecting the students’ ability to perform. Required match funding should be
free of federal regulations. The required match should have the flexibility of leveraged funds, or
perhaps simply be re-defined as required leveraged funds.
4. Which Federal programs should be involved in performance partnership pilots for
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 14
We are uncertain what the implications would be of inclusion of a national program like YouthBuild
in a performance partnership pilot. If it would mean that any of the DOL YouthBuild annual
appropriation would be subtracted from the funds for which local organizations apply, and instead
be added to the pool for the performance partnership, we would be adamantly opposed to
disrupting the existing delivery system in that way.
If it would mean that within a Performance Partnership, if a YouthBuild grant were won by a local
organization it would receive additional flexibility in implementation, that might be desirable,
although it might be better not to use up the capped amount of flexibility since YouthBuild
guidelines are mostly already appropriate.
If it would mean that the Performance Pilot RFP specifically named the YouthBuild model as an
alternative that could be developed or expanded with formula funds, or encouraged local
communities to have a YouthBuild program within the continuum of services that are locally
provided to reconnect young people, that would be fine.
In any case, local YouthBuild leadership should be included in the local collaboration to expand
impact through shared knowledge and partnerships.
5. What has been your experience with other Federal initiatives that address issues related
to disconnected youth by facilitating comprehensive, multi-system approaches and using
existing resources in more coordinated and comprehensive ways, such as Promise
Neighborhoods and Choice Neighborhoods within the Neighborhood Revitalization
Our direct experience with such programs is limited. However, federal initiatives have always
depended on the quality and integrity of the leadership at the local level. There is always potential
for concentration of political control and distribution of resources based too much on relationships,
as well as potential for getting bogged down in endless meetings.
6. Do you see an opportunity to use the Pay for Success model which is currently being
pursued under existing authority by the Departments of Labor and Justice, but which could
potentially be expanded to other areas such as programs serving disconnected youth?
No, we don’t think it would be wise to mix the Pay for Success model with the proposed
Performance Partnerships. Both of them are untested, and the complexity of linking them seems
III. Outcomes, Data, and Evaluation Design
1. What are the key outcomes that pilots should measure, and what indicators should be
used to track intermediate and long-term success for youth?
YouthBuild USA staff, directors at local programs, and young people in the National YouthBuild
USA Affiliated Network have chosen the following benchmark and outcome measures:
Number of applications. Demand for the services is a key indicator of its reputation among
the constituency served. Programs with excess demand should be expanded.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 15
Attainment of one or more industry recognized certificate. This is an intermediate success
measure. Most certificate programs don’t take a long time to complete, so students can feel
Attendance and Completion. These are important indicators of program quality. If the
experience is positive the young people want to be there every day to complete the
program. These measures provide real-time feedback for management to improve
GED/diploma. This is a key outcome. Attainment of a high school diploma or GED is often
a prerequisite for placement in jobs, college, or the military. It is a critical measure of
success that opens essential doors. It has enormous emotional and symbolic value for
young people who have previously left high school without a diploma.
Educational gains. These are not contingent on skills at entry, so taking them seriously as
outcomes tends to mitigate against the tendency to select the most advanced participants.
It allows programs to accept students reading at second or third grade level without fearing
they will lose their funding by failing to achieve GED/HSD outcomes. Educational gains
have a lasting impact on quality of life. They should be measured in reading and math
using standardized tests.
Placement in post-secondary education and/or employment. These should be measured
separately, but given equal value. The timeframe for achievement should be flexible
enough to capture placement within 6 months after program exit. Placement is critical as an
indication that the young people are landing safely on a path to their goals and the program
has both prepared and guided them adequately. However, it is the most difficult outcome to
achieve because it depends on the national and local economy, is affected by criminal
records, the age and maturity of the participants, availability of child care for young parents,
availability of financial assistance, and the needs of other family members. If possible, this
measure should take into account local conditions. For instance, a program with a 60%
placement rate in a community with a 20% unemployment rate may actually be doing better
than a program with an 80% placement rate in a community with a 7% unemployment rate.
Wages. Wages received at placement are an indicator of the level of preparation provided.
Retention. Retention in job or college should be measured, and more importantly
supported, as funding allows, for 6 months to 3 years.
Post-Secondary Credential Attainment. For those who enter post-secondary institutions,
the achievement of post-secondary credentials should be measured. There is an enormous
college drop-out rate, especially for low-income young people, so systems of support
through to credential attainment are critical, as is measuring the success of this effort. This
is a program unto itself, worth funding.
Decreased Criminal justice involvement. Recidivism as well as any new criminal
involvement should be measured in terms of criminal convictions, not arrests, which could
be unwarranted. A decrease in criminal involvement is critical for society, will save
enormous amounts of money, and is a key indicator that young people have found a
positive set of values and new methods of achieving their goals or at least the
determination to not end up dead or in jail, as many of them expected to do before they
found a good program.
Achievement of Leadership competencies. While there are no widespread accepted
measures of social and emotional maturity, internalization of the ethic of service, or
leadership and civic engagement, these should be taken seriously as indicators of program
success. Programs should be asked to develop or adopt competencies and engage
participants in mastering them and measuring that mastery. (YouthBuild USA has
developed leadership competencies and is currently testing the measurement of them.)
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 16
There are some federal data-collection systems that have counter-productive aspects to them that
should be changed. Below are recommendations regarding some of the systems currently in use:
Do not equate industry-recognized credentials with GED/HSD attainment and lump them
together into one measure. These are qualitatively different and should be tracked
separately. Both have value, and both should be tracked; but the GED/HSD is of greater
long-term value than a single industry-recognized credential, so these should be broken out
Allow measurement of placement at exit from the program, and then measure it again in
the three quarters following placement. In some data systems at DOL, placement cannot
be counted until the quarter after exit. This is a flawed system that results in confusion at
the local level, gaming of the system, or loss of credit for real placements that occur at exit.
Placement should count whenever it is obtained, and programs should be given a full
quarter after exit to achieve placement, but should not have to wait until the quarter after
placement to have it counted the first time. Once a placement is achieved, placement
retention should be measured in the following quarters for as long as the goals of the
program require and the resources allow.
2. What existing data collection mechanisms can be harnessed to track indicators,
outcomes, and participant characteristics?
Web-based data collection systems simplify both the input and extraction of data because the
systems can be accessed from anywhere with an internet connection. Users of those systems
can be trained remotely via webinar and robust communities of developers exist to ensure that
web-based systems keep pace with changing technology. In particular, web-based data
systems that are created with open source technology allow for extension of systems as needed
for individual organizations and for ease of data sharing between organizations and federal and
DOL has developed an MIS system that has proven useful in collecting and disseminating data
reliably from across the country.
3: What are examples of frameworks and protocols for sharing data efficiently across
programs while meeting privacy and confidentiality requirements? What should be the
specifications for additional frameworks or protocols for effective sharing of information?
When looking to frameworks and protocols it would be wise to look for technologies like those
supporting web service standards (Web APIs, RESTful) that many open source frameworks use.
This makes the connection of these systems much easier, and thus the sharing of information can
occur quicker and with good security. Keeping data access behind good permission structure, as
well as allowing approved access through APIs can help foster the exchange of information in
common formats to reduce time consolidating or correlating data. Access to standardized formats
(from both a technical and programmatic side) will allow for more flexible and quicker analysis as
well. Web frameworks like Drupal, Rails, and Django all have advantages here, as well as high
regard and active community development.
4. What are the best examples of communities and programs using data to track progress,
inform course corrections, and evaluate program effectiveness?
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 17
The DOL uses data reports on a very constant basis to manage its YouthBuild program. A weekly
report is issued to federal managers and YouthBuild USA showing on-going cumulative results for
every grantee. This is used for targeting TA, and for developing appropriate training.
5. What evaluation designs should be used to demonstrate improved outcomes or
improved cost-effectiveness of Performance Partnership Pilots?
We advise using the outcome measures described above, and comparing them to the local,
regional, and/or national averages on these outcomes for comparable population groups. Return
on Investment can be calculated against the generic lifetime cost to society calculated by various
researchers (Clive Belfield, Columbia; Mark Cohen, Vanderbilt Univ.)) of young adults lacking a
GED or HSD, being unemployed, committing crimes, and/or being incarcerated or dependent.
Random assignment evaluations are of enormous interest and value, but some of the implications
of this approach need to be taken into consideration. Any success in an RAE depends on its taking
place in a resource-poor environment, where individuals not randomly selected for the program
group simply can not find any comparable opportunities. It is actually a class-based approach to
evaluation. RAEs are not carried out at Harvard, because everyone knows that the students who
don’t get into Harvard can go down the street to Yale, and the resulting outcomes won’t be much
different than for those who go to Harvard. An RAE of interventions in low-income communities
depends on there being no equivalent opportunities down the street.
Ideally, our goal as a nation, and within every community, should be that there is such a rich
network of comparable but varied local opportunities that every individual finds his or her best path.
We want the collective and collaborative impact of the work we do in local communities to result in
the success of every young person. This would result in excellent outcomes for all. A random
assignment evaluation that requires higher outcomes for the “treatment” group than for the
“control” group would show little difference between the two in a truly resource rich environment.
The immediate implications of this on the efficacy of the evaluations is that if there are other good
options for the control group, the treatment may not show decisive comparative impacts,
inappropriately undermining the case for the program being evaluated.
In addition, there are circumstances where RAEs are unworkable, such as when dealing with
public institutions like charter schools that cannot legally enforce the control group’s temporary
embargo on enrollment that RAEs require.
6. How do the Federal Government, States, and local entities ensure that the flexibility
provided through the pilots does not have any adverse effect on the most vulnerable
The only risk arising from added flexibility that occurs to us is that the most vulnerable populations
will not be served if eligibility limitations are removed. We recommend providing a set of eligibility
requirements for low-income disconnected youth and then allowing a 25% waiver of those
constraints. This will preserve a focus on the core target population without excluding
neighborhood residents who will benefit from the opportunities .
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 18
1. What are the legislative, regulatory, or other barriers that impede a community's ability to
implement the most cost-effective strategies to assist disconnected youth?
The comments below are based primarily on barriers we have experienced at the federal level
A. Eligibility Limitations on All Programs, especially Ex-Offender Programs
Rigid eligibility limitations are counter-productive because the comprehensive services needed by
disconnected youth cross eligibility groups. Foster care youth, youthful offenders, high school
dropouts, high school graduates with skills deficiencies, unemployed youth, need roughly the same
comprehensive services. It is much better for local communities if there are not rigid lines drawn
between groups that incentivize bad behavior or penalize positive behavior (e.g. you can only join
this wonderful program if you committed a crime or have dropped out of high school). It is also
better not to divide young people from each other. Youthful offenders often do better if they are
integrated into a group that has non-offenders as part of it. We therefore recommend a 25%
waiver in all eligibility requirements to provide flexibility for appropriate inclusion at the local level.
B. Food: Not an allowable expense
DOL grantees may not use federal funds to pay for the purchase of food for program participants.
Food should be an allowable cost for programs serving disconnected youth. Indeed, food is one of
the greatest “hooks” for getting young people involved in programming.
C. Age Limitations for Average Daily Attendance Funds (State Level)
Most states have age limitations for average daily attendance funds that are well below age 24.
This prevents second chance charter schools and alternative schools from serving older youth
without special legislation. In California there is legislation that approves ADA funds for
YouthBuild, Service Corps, and Job Corps charter schools through age 24. This has been an
enormous help for re-engaging larger numbers of older youth through charter schools.
D. Competitive Requirements in the Tiering Priorities for AmeriCorps Competitions under CNCS
In its most recent competition in 2011, CNCS changed its competitive process in a way that
mitigates against the selection of grantees who engage disconnected youth in service. This runs
counter to some of the goals of the Serve America Act and the recommendations of the White
House Council on Community Solutions. CNCS should change its tiering to include in its First Tier
some service activities that can best be performed by disconnected youth and explicitly name the
inclusion of disconnected youth as service givers as a first tier (rather than third tier) element.
E. Arduous Technical Assistance and Training Approval Processes at the Federal Level
The recent changes to approval processes at the federal level have made it difficult for CBOs to
receive in a timely fashion the training and TA managed by DOL. The process for approval of in-
person events, conferences, and meetings, plus coaching and online conferences, includes a
multi-step approval system and lengthy processing time, limiting the amount and timeliness of
assistance that grantees may receive.
F. Obstacles to Approval for Inter-agency Collaboration
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 19
The need for approval of collaboration across federal agencies also hampers support to grantees.
Inter-agency collaboration is subject to approval inside each agency prior to commencement. This
process is too lengthy.
F. Travel Embargo for Federal Employees
Federal DOL staff travel has become extremely limited both through budget and approval
processes. They are not able to visit their grantees, to assess grantee success or challenges first
hand, or to become familiar with grantee operations. Federal employees should also be allowed to
attend program conferences and meetings without a strenuous approval process.
G. Student Outcome Benchmarks that are out of Synch with Local Opportunities and Realities
High expectations need to be balanced with the realities of local and national employment
opportunities and outcome targets adapted accordingly. In the current employment landscape
where skilled adults and returning veterans are competing with disadvantaged youth for basic level
jobs, employment targets should not be held to an arbitrarily high level that remains unchanged
from year to year and determines continued funding and legislative judgments. Lacking national
success benchmarks based on real experience for low-income, disconnected youth, CBOs are
sometimes held to unattainable comparisons with school districts serving traditional age students
who have not dropped out. Holding outcome measures artificially high incentivizes CBOs to turn
away the hardest to serve youth. Tying outcome measures to local realities (such as economic
measures) will identify which programs are outperforming their communities.
H. Regulations Prohibiting Promotion of Products
DOL is not allowed to promote any particular product. While this limitation is understandable as a
way of preventing conflict of interest, it is counter-productive when there is a useful or proven
curriculum that might be used to wider benefit. Some standard for approval should be established.
I. Regulations that Operate Against the Letter or Spirit of Program Legislation
Sometimes, public agencies publish a regulation or issue technical guidance that is at odds with
the letter or spirit of the covered programs’ enabling legislation. While such actions undoubtedly
serve valid purposes, they may also be counterproductive both for the individuals to be served and
for the overall outcomes of the program.
One example of such a situation is where the program-enabling legislation allows participants to
receive up to two years of services, but an agency issues technical guidance prohibiting
participants to be served under more than one grant. This means that a participant enrolling in the
final year of a grant cannot also be served under a subsequent grant. As a result, that participant
is restricted to one year’s programming in contravention of the program’s enabling legislation.
While such a practice may make it easier and cleaner for an agency to report program-wide
outcomes because individual participants don’t have to be tracked across more than one grant, it
does a disservice to those participants whose enrollment must be truncated for regulatory
convenience. Furthermore, it can also have a negative impact on the very outcomes the agency is
seeking to track by denying participants access to the full benefits of multi-year programs.
J. Foster Increased Postsecondary Education Partnerships
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 20
The following recommendations are proposals for changes in legislation that would facilitate
engaging CBOs in postsecondary education partnerships that would benefit previously
In the current Higher Education Act (HEA), there are existing provisions for higher education
institutions to partner with high-performing CBOs. For instance, HEA allows TRIO funding
allocated to higher education institutions to pass-through to CBOs, providing a range of student
support services. Unfortunately, these partnerships have been the exception and not the rule.
CBO partnerships have been underutilized and existing HEA provisions have resulted in limited
higher education investments in CBO partners. Reauthorization of HEA should:
Define CBOs working toward postsecondary access and success as eligible entities, so
that every provision of the reauthorized HEA which funds CBO-higher education
partnerships can be accessed directly by either side of the partnership as the lead
agency. Many CBOs are now delivering programming on postsecondary campuses and
committing to shared program models. YouthBuild, Year Up, Gateway to College and
other CBOs serving disconnected youth in close coordination with postsecondary
partners should be recognized as eligible entities for HEA funding.
Require partnerships, so that instead of simply allowing for funds authorized by HEA to
support potential partnerships with CBOs (e.g. TRIO funding), the Act would instead
mandate and strongly incentivize partnership approaches to improve college access and
Fund partnerships with CBOs specifically designed to serve court-involved young people
in creating a Prison to Postsecondary Pipeline strategy. The current version of HEA
includes a Path to Success provision which funds competitive grants to community
colleges working in partnership with juvenile detention facilities. Many CBOs working
with youth have developed specific program approaches for supporting court-involved
young people transitioning into college. CBOs should be recognized as eligible entities in
new and expanded innovation funding for partnerships focused on helping court-involved
young people access and succeed in postsecondary education and training.
Align the Business Workforce Partnership provision of HEA with opportunities to
recognize and fund CBOs to operate on postsecondary campuses as 21st Century
career development leaders. This funding, specifically allocated for job skill training in
high growth occupations for low-income students, should support programs like
YouthBuild, Year Up and other CBOs serving disconnected youth to operate at scale on
community college campuses across the country.
Invest in partnerships that prioritize service and leadership development as key
engagement and retention strategies. The current version of HEA has a provision
allowing for funding of off-campus service projects. Service and leadership opportunities
have been undervalued retention strategies in higher education, especially at community
and technical colleges. Many CBOs have developed programming to integrate service,
leadership, and education for disconnected youth. CBOs should be recognized as
eligible entities for new and expanded innovation funding for partnership funds focused
on service and leadership development as an engagement and retention strategy.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 21
Track success of CBO-postsecondary partnerships and only invest in those collaborative
efforts that improve postsecondary access, retention and success rates above existing
baseline data indicators. Partnerships for court-involved youth, career development
models, service and leadership development programming should all be funded based
on outcome performance measures.
K. Foster Secondary Education Partnerships
Currently there are limited incentives for schools to reach out to dropouts. In reality, concerns
that students who left school will bring down scores and pass rates sometimes serve as a
disincentive for schools to reach out to them. In the reauthorization of the ESEA, we
recommend encouraging and funding LEAs to develop more comprehensive strategies to work
explicitly with disconnected youth in close coordination with CBOs.
Based on the experience of YouthBuild students, graduates and staff, we recommend the
following steps in the reauthorization of the Elementary and Secondary Education Act (ESEA)
relative to partnerships between school districts and CBOs:
Designate a percentage of formula funds specifically for dropout recovery. Require local
education agencies (LEAs) to develop strategies for working with this population and
require them to collaborate with CBOs whenever possible.
Fund alternative education programs (including community based organizations that
provide education) to create multiple pathways to earn high school diplomas and/or
GEDs, including GED-Plus, juvenile justice re-entry programs, and apprenticeships as
part of a comprehensive re-engagement strategy.
Support schools and CBOs engaged in re-engaging disconnected youth to
collaboratively offer credit acceleration through competency based models (instead of
purely seat-time models) as long as students are still able to pass state exit exams,
demonstrate mastery of common core standards, and fulfill graduation content
Invest innovation funding to partnerships improving specific pathways for rural schools.
Outcome and performance-based innovation funds should be made available to rural
school districts and rural CBOs for collaboratively creating new rural pathways. For
instance, investments in reliable, affordable and accessible transportation would
alleviate one of the greatest barriers for rural young people to access postsecondary
education, training and career opportunities. Similarly, improved access to broadband
can expand rural access to quality and affordable education, employment, health and
V. Alternative Pilot Designs
1. Which of the design models would best enable effective pilots at the community level?
We believe the simplest, least confusing, and best approach would be the Formula Grant Model.
We are opposed to pulling funds out of existing national competitive grant programs, diminishing
the funds available for competition.
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 22
However, within the Formula Grant Model it would be important if possible to remove the cap on
funds within the waivers. The imposition of an arbitrary limit on how many federal dollars may be
used in the pilots will limit their effectiveness. If, for example, a community applies for a waiver to
pool funding from three federal programs, and if the community received a total of $30 million from
those federal programs, and if the federal government only grants them waivers on $20 million of
the funds, then the community will have to account for $10 million of the funding streams one way,
and $20 million the other way. This will increase rather than decrease the bureaucratic burden on
2. What is the recommended duration of the performance partnership pilot projects for the
model or models you selected as effective?
We recommend that pilots last for three to five years, with annual progress reviews and corrections
Thank you for this opportunity to comment and for making reconnecting youth a priority for federal
YBUSA Response to RFI on Strategies for Improving Outcomes for Disconnected Youth Page 23