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Frequently Asked Questions About Telework
(Compiled from Telework Listserve)

Question
1. Can an applicant who is participating in a training program designed to place him or her into telework (but has not received a written promise or guarantee of telework employment) qualify for a Telework loan?

Answer
The notice inviting applications for Telework grants published in the Federal register on August 5, 2003, identifies two goals for the Telework Program:

(1) A short-term goal of increasing access to technology for individuals with disabilities through alternative financing mechanisms that are used to purchase computers and other equipment, including adaptive equipment, so that individuals with disabilities can telework from home or other remote sites.

(2) A long-term goal of increasing employment opportunities and competitive employment outcomes for individuals with disabilities.

Providing a Telework loan to an individual with a disability so that he or she can purchase equipment in order to participate in training designed to place him or her into telework or to gain employment as a result of that training would support the long-term goal of increasing employment opportunities and competitive employment outcomes. Therefore, an applicant who is participating in training designed to place him or her into telework and needs equipment to participate in that training or to gain employment as a result of that training can qualify for a Telework loan, and a State may choose to develop and implement its administrative policies and procedures accordingly. Please note that a State with a policy allowing Telework loans to individuals who do not have a guaranteed telework opportunity must ensure that the equipment being purchased and training being provided is directly related to enabling the individual to telework, as would apply to any Telework program.

In general, a Telework program has the discretion to determine whether it will provide loans to individuals with disabilities who are not currently employed or lack a commitment from an employer. If a Telework program chooses to do so, it needs to justify sufficiently its choice to provide a loan by ensuring that the individual will use the equipment to:

  1. become self-employed and operate his or her business from home on at least a part-time basis;
  2. seek telework; or
  3. gain skills that will improve his or her opportunities for telework.

Please note in (a) above, an individual with a disability who is self-employed (or plans to be self-employed) may receive a Telework loan, but that individual must operate his or her business from home on at least a part-time basis. The equipment purchased must be used to support the work that is done from home.

Question
2. (a) Can Telework funds be used to pay for training, supplies, extended warranties, or insurance for devices or equipment?

Answer
A Telework loan must include the purchase of equipment to be used for telework, and cannot be used to pay exclusively for other costs such as training, supplies, warranties, or insurance. In other words, a loan cannot be provided exclusively for training, or to pay for insurance or an extended warranty for a device that has previously been purchased and is not a part of the loan. However, a loan can include non-equipment costs that are necessary to enable the borrower to use the equipment being purchased for telework. Therefore, if an individual with a disability is approved for a loan from a Telework program in order to purchase equipment or an AT device, the cost of an extended warranty, insurance, training, or supplies that will assist in use of the device or equipment can be built into the loan.

Question
2. (b) Can Telework funds be used to pay for repair, maintenance, or upgrades for devices or equipment?

Answer
There may be circumstances in which a device or piece of equipment currently being used by an individual with a disability is no longer meeting that individual's needs. Rather than purchasing a new device or piece of equipment, in some cases the current device or piece of equipment can continue to be used if it can be upgraded or repaired. The Telework program in each State should decide whether or not an individual can take out a Telework loan to pay for repair, maintenance, or an upgrade of a device or piece of equipment. If it has not done so already, a Telework program is encouraged to determine whether or not it will allow loans for such purposes, develop a policy based upon this decision, and develop guidelines for implementing that policy. As applies to all Telework activities, the result of repairing, maintaining, or upgrading equipment should be that an individual with a disability can begin teleworking, can continue teleworking, or can improve his or her teleworking situation.

Question
3. Can Telework programs use their Federal funds to pay for financial literacy training, debt repair, consumer credit counseling, and/or microenterprise skills training for pre-applicants or borrowers?

Answer
The answer to this question depends upon how Telework program plans to provide for the cost of such training or services. While the purpose of Telework grant is to establish or expand a program that provides loans to individuals with disabilities, there are some scenarios under which providing such training or services, herein referred to as "consumer counseling," would be allowed.

Scenario #1: A Telework program may directly provide consumer counseling to an applicant who has not yet been approved for a loan. This consumer counseling would be paid for as part of the administrative cost of operating the Telework program. This would also apply if the Telework program was not providing the service directly, but instead was providing payment to another entity to provide consumer counseling.

Scenario #2: A Telework program may directly provide consumer counseling to an applicant who has been approved for, or has received, a loan. Some Telework programs may choose to add the cost of consumer counseling to this loan or build the cost into any loan processing fees. If the consumer counseling is not paid for as part of the loan, it would be an administrative cost of operating the Telework program. This also would apply if the Telework program was not providing the service directly, but instead was providing payment to another entity to provide consumer counseling.

Question
4. Can Telework Programs use Federal funds to promote the use of telework?

Answer
Just as creating awareness of a Telework program is a viable administrative cost, Telework programs can use funds for the administration of the program to promote Telework. However, these efforts must be focused on creating telework opportunities for individuals with disabilities specifically, and must be directly tied to promoting the use of the Telework program.

Question
5. What is a telework center?

Answer
The notice inviting applications for the Access to Telework Program published in the Federal Register on August 5, 2003, states:

"For the purpose of the purposes of the proposed Telework priority, the term 'telework' encompasses work that can be performed effectively from home or from other remote sites away from the office, such as work on the road or at a telework center."

To be a telework center, the site of the telework center must be in a location that is remote from the employer's main site. Different kinds of telework centers exist, including centers that are established and used exclusively for a particular employer or that are used by multiple employers who rent space at the center. However, the following are not telework centers:

  1. satellite or regional offices;
  2. space rented by an individual who is self-employed; and
  3. centers that are the sole location of a business operation.

Within the above limitations, a Telework program has the discretion to determine whether or not an applicant will be conducting telework from an appropriate telework center.

Question
6. Can a Telework program give preference to an applicant who has telework as part of his or her Individual Plan for Employment (IPE) through a vocational rehabilitation program or as part of a Plan for Achieving Self-Support (PASS) through Social Security?

Answer
Telework programs are required to establish policies and procedures to ensure that access to telework is given to consumers regardless of type of disability, age, income level, location of residence in the State or Indian tribe, or type of device or service for which financing is requested. Given the emphasis on providing equal access for all individuals with disabilities, each applicant must be judged individually on his or her own merits. Just as Telework programs cannot automatically exclude individuals with disabilities who are not using an IPE or PASS, they cannot automatically give preference to individuals with disabilities who are using an IPE or PASS or other similar plan. However, this does not mean that a Telework program is prohibited from using an applicant's IPE or PASS, or an independently developed business plan, as a factor when deciding whether or not the individual is a desirable candidate for a loan.


AFTAP/RESNA
1700 North Moore Street, Suite 1540
Arlington, VA 22209-1903
Phone: 703/524-6686  Fax: 703/524-6630  TTY: 703/524-6639
Email: info@resna.org  http://www.resnaprojects.org/AFTAP

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