PERMIAN BASIN WORKFORCE DEVELOPMENT BOARD OPERATION AND MANAGEMENT OF WORKFORCE SOLUTIONS PERMIAN BASIN WORKFORCE SERVICES Section II SERVICE DESCRIPTION PBWDB Workforce RFP Section II – Service Description May 2015 Page 1 of 13 PROGRAM OVERVIEW The contractor selected through this RFP will manage and operate the Workforce Solutions Permian Basin workforce services which includes providing services to employers and job seekers. The services available within the Workforce Solutions Permian Basin offices must include at a minimum: business services consistent with applicable rules and regulations of the various funding sources, outreach, recruitment, screening, comprehensive assessment, determination of eligible customers for available employment and training programs, case management, counseling, follow up, referrals to appropriate resources, coordination of customer supportive services, and coordination with State agencies. PBWDB has identified three Service Principles under which it expects its workforce contractor to deliver services. These principles should be considered and addressed in response to this RFP. All customers (job seekers and employers) will receive prompt service. All customers regardless of location will be provided uniform high quality service. State and federal performance measures will be met. EMPLOYER SERVICES PBWDB recognizes employers as the primary customer of the Permian Basin workforce system. Employers must have access to a skilled workforce and labor market services to continually increase their competitive advantage and to maximize economic development opportunities. Employer services provided within the workforce system are to be responsive to employers needs for a skilled workforce. PBWDB has identified the following goals to continually meet employer needs. The Workforce Solutions Permian Basin must be recognized as a reliable and consistent resource for businesses, based upon positive customer satisfaction and performance excellence, to address and meet their employment needs. Access to the Workforce Solutions Permian Basin services is easily available regardless of the employer’s location. Dependable high quality services are delivered by providing a skilled workforce through effective job matching which includes utilizing WorkinTexas.com and other resources. PBWDB seeks a contractor with the proven ability to enhance services to the local business community, while reducing the number of unemployment claimants in the local area. Currently, one measurement of success in those activities is identified by the Texas Workforce Commission’s Reemployment and Employer Engagement Measures related to the number of claimants reemployed within 10 weeks. Other employer measures now in place are the number of employer job openings filled, and the number of employers receiving workforce assistance. The successful offeror should indicate a service delivery system designed to achieve these measures. The Workforce Innovation and Opportunity Act specifies a performance measure for employer, “effectiveness in serving employers”, which will be developed. The workforce contractor is expected to deliver employer services including but not limited to the following. Outreach and recruitment. An outreach and recruitment strategy to engage new employers in the workforce system and expanding existing employer partnerships. Job seeker matching/job lead referrals. To assist employers in meeting their workforce needs, employer services staff will identify job seekers matching job requirements and provide quality PBWDB Workforce RFP Section II – Service Description May 2015 Page 2 of 13 referrals. The workforce contractor will provide training and assistance to employers to ensure quality self-service through existing tools. Assessment and testing. On behalf of employers, Workforce Solutions Permian Basin office staff may conduct assessment and testing activities to determine the skills and abilities of prospective employees. The workforce contractor may use standard assessments and tests it has available in the centers or use assessments and/or tests requested by the employer. Job fairs. Employers will be provided several opportunities to participate in both “open” and job specific fairs to initiate contact with job seekers. Employers may also utilize workforce services/facilities to host a job fair for their business. Interview screening and hiring process. On behalf of employers, job seekers will be screened against basic hiring qualification requirements. Employers may receive technical assistance in the activities and skills critical to the employment process. Labor market information services and other data. Employers will be provided with the latest labor market information available via the Bureau of Labor Statistics, Texas Workforce Commission, and other resources. In addition, employers will receive information on tax credits, on-line resources, and external grants available for training current workers (skills development, skills grants for small businesses, self-sufficiency funds, and special grants). Rapid response. Orientation to lay-off requirements rights/responsibilities and best practice information will be provided to employers (subsequent to WARN notification) and meetings with affected employees regarding programs, services, and assistance available to support them through their transition period. Alternatives to downsizing. Contractor staff will assist employers considering downsizing their operations in the areas of research, job restructuring, employee re-qualification, redeployment, and labor pooling. Other appropriate services and/or innovative enhancements. Other innovative enhancements which promote excellence in customer services may be provided to employers. If additional services are proposed, a complete description should be included in the proposal narrative. JOB SEEKER SERVICES Job seekers must have access to high-quality labor market information, quality training, and services that facilitate finding employment or obtaining better jobs. Additionally, job seekers must have access to literacy, education, and workplace skills as needed for employment, education, and career opportunities. PBWDB has identified the following goals to meet job seeker needs. The Workforce Solutions Permian Basin offices are recognized as the resource place for job seekers, based upon reputation for customer satisfaction and performance excellence, regardless of the job seeker’s skills and educational achievement. Access to the Workforce Solutions Permian Basin services is easily available regardless of the offices’ locations. Dependable high quality services are delivered to meet the labor market needs of job seekers, current employees, and youth by providing effective job matching which includes utilizing WorkinTexas.com and other resources. Coordination with businesses, economic development, community-based organizations, and public entities to maximize resources and avoid duplication of service. PBWDB Workforce RFP Section II – Service Description May 2015 Page 3 of 13 The workforce contractor must be capable of designing a seamless service delivery system that maximizes performance driven outcomes, including entered employment, employment retention, and education achievement, for all job seekers. The successful Offeror should indicate a service delivery system designed to achieve all contracted performance measures for all job seekers regardless of the program from which they are served. The services provided by the workforce contractor to meet job seekers’ needs can be grouped into three categories: Universal services - labor exchange for the general population, labor market information, resource centers, information on unemployment benefits, and other services. Specialized services - case management, comprehensive testing and assessment, training, and assisted job search. Support services - those reasonable and necessary services needed by a job seeker to obtain and retain employment consisting of, but not limited to, child care services, transportation, training tools/equipment, and testing fees, etc. The workforce contractor delivers specific job seeker activities, including but not limited to, the following. Outreach and recruitment activities inform the community of the availability of the services of the Workforce Solutions Permian Basin offices, especially focusing on targeted populations which include economically disadvantaged, dislocated workers, unemployment insurance claimants, individuals dependent upon public assistance, persons with disabilities, persons without a permanent residence, veterans, under-employed individuals, ex-offenders or recent parolees, persons entering the workforce for the first time, individuals with literacy barriers, and others. The workforce contractor will work closely with community partners to outreach these individuals for services available within the Workforce Solutions Permian Basin offices. Case management, counseling, and follow-up is provided to ensure achievement of positive outcomes. It is the responsibility of the Workforce Solutions Permian Basin office staff to ensure that barriers to employment or training are overcome by the referral to appropriate resources and that the customer feels that he/she has an advocate in achieving his/her career goals. It is also the responsibility of Workforce Solutions Permian Basin office staff to serve as an advocate for the customer in seeking informal resolution to complaints regarding quality of services. Workforce Solutions Permian Basin office staff will assist when appropriate in follow-up activities to document customer outcomes. Documentation of these activities is recorded in the customer’s file and in Texas Workforce Commission’s designated information technology data automation system(s). Comprehensive testing and assessment of customer’s basic skills, occupational skills, educational background, prior work experience, employability, career interests and aptitudes, and the need for supportive services is conducted. An analysis of this information is the basis for realistic employment and training goals which the Workforce Solutions Permian Basin office staff develops into an Individual Employment Plan (IEP) with the job seeker in one or more counseling sessions. Additional labor market information, such as targeted occupations, immediate employers and training provider data, is provided to the job seeker at this time so that he/she may make informed choices. Training services are available within the Workforce Solutions Permian Basin offices for job seekers who are unable to find employment. A job seeker may be referred to job readiness training, Adult Basic Education, English as a Second Language, General Equivalency Diploma, or other services. Eligible job seekers (WIA/WIOA adult or dislocated worker) may receive training in PBWDB Workforce RFP Section II – Service Description May 2015 Page 4 of 13 targeted occupations identified by PBWDB and based on customer choice. Training services paid by the Workforce System are provided and documented based on the issuance of Individual Training Account (ITA). The selected contractor will be fully responsible for the fiscal and program management of ITAs. (For information on the targeted occupations, please refer to PBWDB’s webpage at: www.workforcepb.org.) Supportive services are discussed at the time of initial assessment and are addressed to remove employment barriers. These currently include, but are not limited to, referral for child care assistance, transportation assistance, financial counseling, GED testing, tools and uniforms, and testing for licensing or certification for employment, as appropriate. These services are provided on a case-by-case basis, as the need is identified and to the extent that funds are available. Referral to appropriate resources is made to community partners to assist in meeting the job seeker’s needs. SERVICES SUMMARY The following table itemizes the variety of services delivered and/or provided to the workforce customers of the Workforce Solutions Permian Basin system. PBWDB Workforce RFP Section II – Service Description May 2015 Page 5 of 13 WORKFORCE SERVICES BY CUSTOMER GROUP UNIVERSAL PROGRAM JOBACTIVITY OR SERVICE POPULATION SEEKER Outreach x x Information and orientation to services x x Access to job listings, on-site and on-line x x Information on required job skills x x Information on educational opportunities and skills training x x Information on program/center performance x x x x x x x x x x x x x x x x Assistance in accessing resources for business support and training Assistance accessing financial aid for education/training Information on child care and other available support services Information on unemployment insurance and/or assistance with filing appeals Information on tax incentives and credits Access to copiers, fax machines, telephones and other resources Use of workforce facilities for interviewing and/or employee training Registration for services Intake/eligibility determination Initial or basic assessment of skills, aptitude and interests Comprehensive assessment of skills, aptitude and interests Assessment of need and/or provision of Support Services on-site and by referral Development of individual employment plan Career exploration and counseling x x x x x x x x x x x x x x x x x x x x x Employment planning workshops Job search assistance x Job development Job matching/placement Posting of job openings Referral to jobs/employers Screening of applicants Job readiness and job search workshops Integrated Case management Post-employment services On-the-job training Customized training Individual training accounts Referral to basic education, GED, literacy and Limited English Proficiency programs Crisis counseling, financial workshops and assistance with lay-offs PBWDB Workforce RFP Section II – Service Description x x x x x x x x x x Information on a variety of employment issues Labor market information EMPLOYER x x x x x x x x x x x x x x x x x x x May 2015 Page 6 of 13 INTEGRATION OF SERVICES AND COORDINATION OF SERVICES The integration of services within the Workforce Solutions Permian Basin system is critical to ensure an effective and efficient use of staff and funds and to ensure a service delivery system that seamlessly addresses customer needs. The Service Delivery Plan submitted in response to this RFP should address how the Offeror will integrate the workforce services within the framework of the PBWDB’s Service Principles. The WIOA emphasizes and mandates the development of partnerships to effectively serve not only the universal population but the hard to serve. The Texas Model currently has integrated Wagner-Peyser, Temporary Assistance for Needy Families, and Supplemental Nutrition Assistance Program into the workforce system of services. Individuals with disabilities and those with literacy/language barriers will also become target populations for the workforce system. The selected contractor will be expected to develop, foster, and grow partnerships in order to coordinate and collaborate services for our common customers. PBWDB considers the coordination and collaboration of its workforce contractor with businesses, economic development, community-based organizations, vocational rehabilitation, adult education and literacy programs, and county/state/federal agencies essential in order to leverage available funds and resources to meet customer needs. PBWDB also views the integration of child care and workforce programs as an essential component to a seamless, cohesive service delivery system that we desire for our customers. It is the expectation of the PBWDB that the selected Offeror and the child care contractor will develop and implement a plan, in cooperation and collaboration with PBWDB, to integrate both services into a more unified whole for the betterment of the customers we serve. SCOPE OF CURRENT OPERATIONS The selected Offeror will assume responsibility for the operation and management of all the Workforce Solutions Permian Basin workforce offices. The following summarizes the current operations of those offices. OFFICES. PBWDB currently has five (5) workforce offices located in Ector, Howard, Midland, Pecos, and Reeves counties. A sixth office is operated by the child care contractor. Case management operations are centralized in the Ector County (Odessa) and Reeves County (Ft. Stockton) offices. Case management is offered in the other offices on a scheduled basis with staff traveling to those locations. Employment services to the universal population of employers and job seekers is provided at all locations. Workforce offices are co-located in four of the five locations. In Midland, Big Spring, and Pecos the offices are located on the local community college campuses. The fourth location in Ft. Stockton is co-located with a community-based organization. PBWDB is responsible for and holds all space/building leases at all locations. STAFF The total number of positions currently in the Workforce Solutions workforce offices includes 18 contractor positions, eight (8) Texas Workforce Commission employees, five (5) temporary employees, and one (1) work experience youth. In addition, Experience Works, Texas Veteran Commission, and the 21-1 Texas Permian Basin Information and Referral programs are co-located in the Odessa office. PBWDB Workforce RFP Section II – Service Description May 2015 Page 7 of 13 PBWDB encourages the entity awarded a contract through this RFP to give first employment consideration to current Workforce Solutions Permian Basin office employees who may be displaced as a result of this procurement. However, the awarded entity should make an independent analysis and projection for necessary staffing. The scope of staffing must include transition planning and the consideration of qualified available workforce professionals currently employed by the system. SERVICE LEVELS For the period October 2014 through February 2015, the Permian Basin Workforce Solutions system provided workforce assistance to 1,430 employers. The Permian Basin workforce system served 14,391 job seekers from October 2014 through February 2015. The number of active cases and the number of cases in follow-up are as follows. Program WIA Adult WIA Dislocated Worker WIA Youth TANF/Choices SNAP E&T SNAP E&T Able-bodied Adults without Dependents Trade Adjustment Act Active Cases As of 4-23-15 17 13 17 17 53 Cases in Follow-up 10/14 – 4/23/15 58 13 20 n/a n/a 24 n/a 2 n/a EQUIPMENT AND MATERIALS The Workforce Solutions Permian Basin offices have sufficient equipment to meet the current staffing levels including computers, printers, copiers, fax machines, and office furniture. In addition, the resource rooms and training labs have an adequate number of personal computers and office furniture. Any new purchases of additional equipment is made by PBWDB. The contractor will be responsible for the purchase of consumable supplies. PBWDB has software to record, track, and manage Individual Training Accounts (ITA). The entity awarded this contract will continue to use this ITA software. OPERATIONS BUDGET The October 2014 through September 2015 allocation to the workforce contractor is $1,850,861.28. This includes funding for the operational costs associated with staff, travel, consumable supplies, etc. and direct customer services (training and supportive services). PBWDB requires a minimum of forty percent (40%) of the Workforce Investment Act/ Workforce Innovation and Opportunity Act funds be used for direct customer services. The Offeror determines how much they want to budget for WIA/WIOA direct training (tuition, fees, books, etc.) and support services, but the minimum requirement must be met. The current contractor’s total allocation is $1,850,861.28. From this allocation, $535,474.98 is for direct customer services in all programs and $1,315,386.30 for the contractor’s operational costs. PBWDB Workforce RFP Section II – Service Description May 2015 Page 8 of 13 Budgets for the purpose of this procurement may include, as applicable and not limited to, salaries, benefits, travel, consumable supplies, insurance and bonding, audit services, professional services, indirect costs, profit, performance incentives, and all pass-through funds. DETAILED FUNDING INFORMATION Federal and state funds finance the workforce center system. The funding for WIOA/WIA becomes available July 1. Funding for the remaining workforce programs begins October 1. A portion of the full allocation awarded PBWDB from the Texas Workforce Commission to provide workforce services in the Permian Basin is set aside for the operational costs provided by PBWDB. PBWDB’s operational expense is for the infrastructure costs of the workforce programs. This includes lease space, utilities, janitorial services, communication (local and long distance phone service, Internet, phone systems), copiers, and IT systems (hardware, software, etc.) used by the workforce contractor. The contractor has a separate operations budget for all other costs associated with operating the workforce services programs. The responses given in the Proposed Service Delivery Plan section should take into consideration the amount of funds needed by a contractor to provide the expenses associated with their operational costs and direct customer services. The funding levels below are the allocations to the workforce contractor for contract year 2014-2015 for the Permian Basin. PBWDB has not received any preliminary projections for the new funding year for any of the programs. The responses given to the questions asked in this RFP should take into consideration the amount of dollars available and the expected number of customers to be served to meet the performance measures. The selected contractor will be expected to adjust their operations budget and levels of service in accordance with actual funding levels, all subsequent changes in those levels, and the mandated performance measures. PROGRAM Workforce Investment Act (Adult, Dislocated Worker, and Youth) TANF/Choices ALLOCATION CONTRACT YEAR 2014 – 2015 $870,219.96 782,985.33 SNAP Employment and Training (E&T) 86,822.98 SNAP E&T Able Bodied Adults Without Dependents 94,453.01 Trade Act Services 16,380.00 Total $1,850,861.28 The Budget Instructions in Section IV – Forms details how PBWDB calculates profit and incentive. The maximum potential profit an entity can earn as well as the maximum potential incentive is held by PBWDB and paid when it is earned. The potential profit and incentive is not included in the contract allocation and is not included in the amounts listed above. The Allocation Contract Year funds are the amounts available to the contract for operations and direct customer service. PBWDB Workforce RFP Section II – Service Description May 2015 Page 9 of 13 PBWDB receives funding to support the Wagner-Peyser staff (travel, supplies, space, etc.). That funding remains with PBWDB and is not passed-through to the workforce contractor. PBWDB is responsible for drawing down and distributing funds to the workforce services contractor in accordance within established policies and procedures. PBWDB reserves the right to de-obligate and reallocate funds before the contract award and throughout the contract period. The workforce services contractor will be reimbursed based on actual expenses and the total amount paid will not exceed the negotiated budget. The obligations of the Board under this RFP and the subsequent contract with the selected Offeror are expressly contingent upon the availability of funds for such purpose under the applicable federal, state, or other funding sources. DEFINITION OF KEY TERMS Allowable Costs: “To be allowable, a cost must be necessary and reasonable for proper and efficient administration of the program, be allocable thereto under these principles, and except as provided herein, not be a general expense required to carry out the general (i.e. non-Board funded) business of the sub-recipient. Costs charged to the program shall be consistent with those normally allowed in like circumstances in non-federally sponsored activities and with applicable state and local law, rules, and regulations…” Board – refers to the Permian Basin Workforce Development Board. Child Care Services – the service delivery system used by PBWDB to administer the subsidized child care program for eligible customers. Choices - a term describing the service delivery model with primary emphasis on the employment of adult Temporary Assistance to Needy Families recipients, including a “work first” strategy with private, unsubsidized employment at the earliest opportunity. Collaboration – resources that work to meet a common goal. Individual parties give up some of their autonomy, which results in a greater goal that no one entity could achieve alone. Common Measures – Performance measures for job seekers served through the workforce system. The current common measures are: Staff-Assisted Entered Employment, At Risk Entered Employment Retention, Total Job Seekers Education Achievement, WIA Youth Placement in Employment/Education, and WIA Youth Literacy/Numeracy Gains. Contractor – the legal entity to which a service provider contract is awarded and which is accountable for the use of the funds. Coordination – resources that work together in order to have harmonious action and/or to prevent the duplication of services. Customer -- an employer, job seeker, youth, parent/caregiver, child care provider, or educational institution that participates in a PBWDB funded program. Job seeker customers in specifically funded PBWDB Workforce RFP Section II – Service Description May 2015 Page 10 of 13 programs may have to be certified eligible to continue to receive services through those program funds (e.g. case management, training etc.). Customers may also include external entities, such as community based organizations, in which a partnership/collaborative/coordinated relationship has been established. Debarment -- In accordance with Federal Executive Order 12549, an action taken by a debarring official in accordance with 45 CFR Part 79 to exclude a person from participating in a covered contract. A person so excluded is “debarred”. Dislocated Worker -- means an individual as referenced under WIA, Title I, Section 101 (9) and (10). Employers -- refers to all establishments of any size, organized as sole proprietorships, partnerships or corporations engaged in legal commerce who hire employees for money wages under conditions conforming to State and Federal labor laws. Supplemental Nutrition Assistance Program Employment And Training (SNAP E&T) -- a program to assist SNAP recipients to enter employment and training activities which promote long-term self-sufficiency, authorized under the Food Stamp Act of 1997, as amended by the Person Responsibility and Work Opportunity Reconciliation Act of 1996 (also called the Welfare Reform). Integration – the coordination of separate parts into a unified whole. Contractor establishes positive working relationships with internal customers in order to provide an integrated service to recipients of the workforce services programs. LWDA – Local Workforce Development Area PBWDB – Permian Basin Workforce Development Board Reasonable/Necessary Cost - A cost is reasonable if, in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Consideration shall be given to: (a) whether the cost is a type generally recognized as ordinary and necessary for the operation of the organization or the performance of the award; (b) the restraints or requirements imposed by such factors as generally accepted sound business practices, arm’s length bargaining, Federal and State laws and regulations, and terms and conditions of the award; (c) whether the individuals concerned act with prudence, considering their responsibilities to their organization, employees, customers, the public at large, and the Government; (d) whether costs are consistent with established practices of the organization and do not unjustifiably increase the costs. Reasonableness of costs may be established by comparison with other proposals (best price – same product), historical data, comparison with prior in-house costs, and/or comparison with similar labor market costs. Targeted Occupations List – A list of occupations and industries that have been targeted as high growth/high wage in the Permian Basin. The current list can be found on our website at www.workforcepb.org. Texas Workforce Commission (TWC) is the state agency that administers the Texas’ workforce development system through the consolidation of job training, employment and employment related education programs, including Choices, SNAP E&T, and Training, WIA/WIOA, Employment Services, and PBWDB Workforce RFP Section II – Service Description May 2015 Page 11 of 13 Child Care Services through contracts with local workforce boards. TWC administers Texas’ unemployment compensation insurance system. Trade Act -- A program that provides reemployment services which may include training and job search/relocation assistance to individuals who lose their jobs due to foreign imports or shift in production to foreign countries. Sarbanes-Oxley Act (Sox) -- This 2002 act contains significant protections for corporate whistleblowers. Supportive Services -- refers to services following an individual’s assessment which are determined to be necessary to enable an individual eligible for program services under WIA/WIOA, Choices, or SNAP E&T but who cannot afford to pay for such services. Supportive services may include transportation, child care, counseling, and other reasonable expenses required for participation. The universal population may receive referrals from the workforce contractor to other agencies offering/providing supportive services they need. PBWDB sets limitations on the amount of supportive services paid and the frequency that a program participant may receive supportive services. Temporary Assistance for Needy Families (TANF) -- a financial assistance program provided through the Texas Health and Human Commission to persons meeting certain residency, income, and resource criteria as provided for under the Personal Responsibility and Work Opportunity Reconciliation Act and the Temporary Assistance for Needy Families block grant. The Workforce Information System For Texas (TWIST) -- is the automated management information system; also called client management system used by all Texas Workforce Boards. Workforce Innovation and Opportunity Act (WIOA) – this act supersedes the Workforce Investment Act effective 2015. It provides workforce activities through statewide and local workforce systems that increases the employment, retention, and earnings of customers, and as a result, improves the quality of the workforce, reduces welfare dependency, and enhances the productivity and competitiveness of the nation. WIOA is a collaborative effort between the Federal Departments of Labor, Education, and Health and Human Services to ensure workforce services are also offered to individuals with disabilities and adults requiring adult education services. Workforce Investment Act (WIA) -- the Workforce Investment Act of 1998, Public Law 105-220. This act provides workforce activities through statewide and local workforce systems that increases the employment, retention, and earnings of customers, and as a result, improves the quality of the workforce, reduces welfare dependency, and enhances the productivity and competitiveness of the nation. Workforce Service Provider - An entity or individual under contract with a local workforce development board to operate: 1) one or more Workforce Solutions Offices, or 2) one or more programs (e.g. child care, workforce) or components of one or more programs (e.g., issuing checks for youth participating in summer employment or performing child care billing). Workforce Solutions Permian Basin – Local brand name that refers to the entire workforce system in the Permian Basin which includes the Board, the workforce programs, and the child care program. PBWDB Workforce RFP Section II – Service Description May 2015 Page 12 of 13 Workforce Solutions Permian Basin Office – refers to the Workforce Solutions Permian Basin offices/centers that provide workforce services and child care services to job seekers, employers, youth, low-income adults/families, dislocated workers, TANF and SNAP recipients. PBWDB currently has six Workforce Solution Offices in the Permian Basin, five that offer workforce services and one offering child care services. Work In Texas (WIT) -- the Texas Workforce Commission Internet based job matching and referral system for employer and job seeker customers. Terms not specifically defined above or elsewhere in this document shall be construed as defined in the program regulations, any amendments pursuant thereto; the TWC Financial Manual for Grants and Contracts, TWIST Manual, state policy/issues, or other applicable laws; or such usage as is commonly accepted by funding agencies and PBWDB. PBWDB Workforce RFP Section II – Service Description May 2015 Page 13 of 13