2007.07.27: July 27, 2007: Headlines: Congress: Legislation: Speaking Out: PCOL Exclusive: 18. Testimony of Chuck Ludlam and Paula Hirschoff on S. 732: The Peace Corps Volunteer Empowerment Act: Peace Corps Leave Policies

Peace Corps Online: Peace Corps News: Special Reports: July 27, 2007: Comments on the Peace Corps Volunteer Empowerment Act by two RPCVs now serving their second tour in Senegal: 2007.07.27: July 27, 2007: Headlines: Congress: Legislation: Speaking Out: PCOL Exclusive: 18. Testimony of Chuck Ludlam and Paula Hirschoff on S. 732: The Peace Corps Volunteer Empowerment Act: Peace Corps Leave Policies

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18. Testimony of Chuck Ludlam and Paula Hirschoff on S. 732: The Peace Corps Volunteer Empowerment Act: Peace Corps Leave Policies

18. Testimony of Chuck Ludlam and Paula Hirschoff on S. 732: The Peace Corps Volunteer Empowerment Act: Peace Corps Leave Policies

The Peace Corps seems to assume that the best way to keep Volunteers from temptations is to strictly limit the number of days per month "out of site," four days per month, for example. Volunteers are required to contact their APCD to secure approval in advance whenever they take these days or otherwise leave their site. These are not vacation days; they're more like weekends or respite time. Weekends and American holidays do not exist in the Peace Corps world, except for staff (which creates some resentment among Volunteers). Other out-of-site policies are that a Volunteer "should not be away from his/her site for more than one weekend in any month (a weekend is considered to be any two consecutive nights, not counting travel time)," and "No Volunteer site absence should last longer than two consecutive nights." A final policy is that "Absences of longer than four (4) consecutive days will generally be considered as vacation (leave)." Administrative Separation is the ultimate sanction for those who violate these policies.

18. Testimony of Chuck Ludlam and Paula Hirschoff on S. 732: The Peace Corps Volunteer Empowerment Act: Peace Corps Leave Policies

Peace Corps Leave Policies

The Peace Corps regulations regarding leave—vacation, medical, job related, leave without allowances (LWOA)—and especially time "out of site"—represent a counter productive en loco parentis approach to managing Volunteers. They embody a lack of respect for Volunteers treating young and old as if they were adolescents. The Volunteers sense this and often violate the leave policies inadvertently or advertently. The whole structure undermines trust between the Volunteers and management. The policies are badly in need of reform.

The general philosophy of the Peace Corps regarding leave makes sense. Manual Section 220 states,

In order to be effective and to meet the goals of Peace Corps and your host communities, Volunteers should remain at their sites as much as possible. Their presence in their community enables them to build positive, trusting relationships, and to work with the people associated with their primary activity. It also enables them to meet other host-country nationals, establish credibility within the larger community, better understand the opportunities for the transfer of skills, and become involved in secondary activities.

Cultural immersion is tough, but it's the only way to learn the language and culture, and to succeed in your work. It can be exhausing at first to live in a community where you have no privacy, no one with whom to speak English, and no one who understands your Western needs or work goals. Volunteers need to be patient and gut this out. When they do, they can find themselves in a rich cross-cultural experience that forever changes their lives.

Chuck was the first Westerner who had ever been to the region of Nepal where he was posted. He often went two or three months with no contact with the outside world or another Volunteer. During this time he had no mail, phone contact, or emails. Paula often went for long periods similarly isolated. This type of isolation in the Peace Corps is largely a thing of the past. Cell phones now connect most Volunteers to friends and family, and cyber cafes have proliferated.

This means that today there are greater temptations and opportunities to communicate by cell phone or email, arrange rendez vous to socialize in town, or watch videos. Many Volunteers straight out of colleges, where a drinking culture sometimes prevails; thus, there are additional temptations. This is particuarly true in cultures where alcohol consumption in public is not permitted or appropriate. Given the overwhelmingly young demographics of the Peace Corps, managers have legitimate concerns about avoiding incidents that might harm individuals or the Peace Corps program.

Running parallel to the leave regulations, the Peace Corps goes to legitimate lengths to remain current on the location of the Volunteers. When emergencies occur at home, Volunteers need to be contacted quickly. When political crises occur, Volunteers need to be warned or even evacuated. All Volunteers are trained in an Emergency Action Plan. However, leave and contact information are two separate issues. Unfortunately, they often get conflated in the Peace Corps.

The Peace Corps seems to assume that the best way to keep Volunteers from temptations is to strictly limit the number of days per month "out of site," four days per month, for example. Volunteers are required to contact their APCD to secure approval in advance whenever they take these days or otherwise leave their site. These are not vacation days; they're more like weekends or respite time. Weekends and American holidays do not exist in the Peace Corps world, except for staff (which creates some resentment among Volunteers). Other out-of-site policies are that a Volunteer "should not be away from his/her site for more than one weekend in any month (a weekend is considered to be any two consecutive nights, not counting travel time)," and "No Volunteer site absence should last longer than two consecutive nights." A final policy is that "Absences of longer than four (4) consecutive days will generally be considered as vacation (leave)." Administrative Separation is the ultimate sanction for those who violate these policies.

The out-of-site policies are a major source of friction between Volunteers and management. Compounding the problem is confusion about whether the out-of-site days are for a respite or for work reasons. Volunteers have many legitimate work-related reasons for leaving site. For example, a) to attend functions sponsored by Peace Corps, such as In-service Trainings (ISTs), workshops and conferences; b) to travel to the capital city for programmatic, training, administrative or medical reasons; c) to travel to a nearby town or regional capital to collect mail, go to the bank, replenish supplies, attend a regional meeting, attend to Peace Corps business, or use a cyber café to communicate with family, friends or other Volunteers; d) to use the computers at a regional Peace Corps house to prepare quarterly reports and other documents and use cyber cafes for research relevant to projects; e) to visit other Volunteer sites within the region or outside the region to provide or benefit from professional development activities or to support other Volunteers; f) to provide peer counseling to other Volunteers; g) to travel with counterparts or work partners to meet with NGOs, Senegalese government officials, or funding sources in support of village projects; and h) to travel to other sites within Senegal to better appreciate our host country and its culture and to attend cultural events and celebrations. Determining whether one is taking out-of-site leave or some other sort of leave is often impossible. In many cases, a trip has multiple purposes.

As a result, many Volunteers ignore the requirements that they seek approval and provide notice. The system is simply too complicated, convoluted, and condescending. The overall tone and effect of these regulations breeds resentment. Because the APCDs are the police for this system, they become alienated from the Volunteers they are supposed to support (emotionally and technically). Telling Volunteers that they must remain in their villages under threat of discipline is not the best way to persuade Volunteers of the benefits of cultural immersion.

Every organization has a few who do not take their work seriously. A few, very few, Volunteers fit this description. But it makes no sense to impose a counter-productive regulatory scheme presuming that every Volunteer is trying to skirt work in an attempt to "catch them." This is over-kill and not worth the considerable price.

A more positive approach to these issues is needed. The best way to keep Volunteers happy and engaged in their work and immersed in their village culture is for the Peace Corps to provide training and support that will enable the Volunteer to thrive at his or her site. It must design programs that give Volunteers a reasonable prospect for success at their sites and give them substantial information on possible secondary projects. If a Volunteer is found spending too much time away from site, the Peace Corps should offer training and support to reverse the tendency. Penalizing Volunteers just demoralizes them.

The Peace Corps needs to experiment with fewer threats and more support regarding leave. There are four areas in which these experiments should take place.

1. Implementation of Out-of-Site Policy: When the APCDs are assigned to police the leave system, particularly the out-of-site limitations, their relationship with the Volunteers suffers. Moreover, the constant bureaucratic task keeps these high level officials from more substantive work. A better alternative might be to provide that when Volunteers leave their site overnight, they notify the Peace Corps in one of three ways: a) Call an answering machine at the Peace Corps country headquarters; b) Send an email to an address at the Peace Corps headquarters; or c) Notify their APCD by cell phone.

They would be asked to report name, destination, dates at the destination, names of Volunteer traveling companions, reason for the travel, and expected time of return to site. They should note if they are traveling to a location without cell phone reception. All Volunteers would be given a plastic card with the answering machine number, email address, check list of information to be provided and a list of the possible reasons for being out of site. Then each day the Peace Corps headquarters would check the answering machine and email address and compile a list of the information provided by the Volunteers on an Excel spreadsheet. One copy would go to the country Security Director.

The APCDs would periodically review the pattern and reasons for absences of the Volunteers from their sites. If a Volunteer has been absent too often from site, the APCD would contact the Volunteer to determine whether the Peace Corps could give support to increase the time at site. The APCD and Volunteer might enter into an agreement about the support the Peace Corps may provide and the expectations of the Volunteer. This system would give the Peace Corps the information needed in case of emergency, but not force the APCDs to serve as police. It would focus on positive intervention, not penalties and threats.

Finally, the Peace Corps measures leave "door to door," counting travel time between sites as part of the leave. This is no problem for Volunteers who live in or near a town or the capital city, but for Volunteers in remote sites or sites where poor road conditions substantially delay travel, a good deal of their leave can be eaten up simply in transit. The policy should be more fair and flexible.

We do not propose that the legislation address these complicated issues. The rules need to be localized in response to the conditions of individual countries. But a positive, reinforcing, non-policing approach such as we suggest is consistent with the themes of this legislation—the need to listen to, respect and empower Volunteers.

2. Job Related Leave: Domestic vs. International Travel: The Peace Corps job-related leave policies are counter productive to the goal of performing serious development work and should be modified.

Volunteers often leave their sites to undertake job-related activities in or outside of their region. This work can involve attending Peace Corps sponsored events or trainings, attending sector-based work conferences, supporting other Volunteers' projects, meeting with NGO, governmental, or private partners, or extending projects developed locally to a regional or national level. Less common are work-related trips to another Peace Corps country, to the U.S., or to a third country where the Peace Corps is not active.

In fact, it is fairly easy for Volunteers to gain approval for work-related travel in country, as some of the relevant policies are relatively flexible. According to Peace Corps Manual Section 218, work travel for Volunteers that “is part of a Volunteer’s assignment or incidental to it will be paid in the country of assignment by the Peace Corps, the host country, or the project donor.” Since the burden of proof for the work's relevance to the Volunteer’s assignment is purposely vague, country managers have a great deal of leeway to allow work-related travel in country. Moreover, since the Peace Corps is not obliged to fund this travel in all cases, but can cede responsibility to the host country or a project partner, budget constraints are less of a limiting factor. In practice, managers are free to use their judgment to apply work travel status, and do not typically concern themselves with the source of the sponsorship (most such trips are unsponsored) provided to Volunteers. This is a good model, as it allows Volunteers and managers to build an organic understanding of the limits on Volunteer projects, and minimizes administrative obstacles to work at the regional or national level.

However, not all job-related leave requests for travel in country, are granted because of the Peace Corps' limited definition of what constitutes a "Volunteer's work." The standard definition is limited to work that takes place in the Volunteer's assigned site. Apparently this definition is intended to minimize a Volunteer’s out-of-site time. The Peace Corps Manual provides no guidance on the value of a work project with national or regional significance compared to the value of the Volunteer's time at site. The latter value automatically prevails regardless of the opportunity for the Volunteer to expand his or her project at the national or regional level. Volunteers who have served for at least a year at site and have developed regional or national projects should be able to apply for a change in the status of their assignment to reflect their work realities and opportunities. If they have demonstrated good community integration and their work has naturally expanded beyond their community, they should be allowed to follow it and apply it nationally or regionally. Stifling the talented Volunteers with the impressive projects is not a wise management or development strategy. The definition of what constitutes a Volunteer's work must be expanded.

The approval process for job-related travel internationally is even more convoluted and counter productive. The definition of what constitutes a "Volunteer's work" remains a major problem, but even worse Peace Corps Manual Section MS 218 notes that “extraordinary or long-distance travel, including travel to the U.S. or a third country, will be provided under a separate travel allowance granted by the Country Director. Volunteers authorized extraordinary travel will receive economy or coach class transportation, or the equivalent.” This language imposes one near-insurmountable obstacle to international job-related travel—the condition that the Peace Corps pay for the Volunteer's travel to third countries while on Peace Corps business, which is frankly improbable given the state of most country budgets. Moreover, once the Volunteer has arrived in the country of destination, the Peace Corps is obliged to pay a per diem. As if to make things more complicated, if the destination is another Peace Corps country, the receiving country is responsible for the per diem, but only if it has requested the Volunteer’s travel (in this case, the country acts like a project sponsor). Countries will do almost anything to avoid adding items to their budget, so that sponsored travel for Volunteers becomes a game of seeing which country administration will give in and request the travel, thus assuming responsibility for the Volunteer’s per diem and other expenses.

Clearly, these rules are not designed to facilitate Volunteer travel to other countries, no matter how great the opportunity for conducting serious development work. Some Peace Corps managers have worked around these barriers by allowing Volunteers to take vacation days for job-related travel to other countries, without offering to pay a per diem, and later giving back the vacation days. This is not an above board method of handling the problem because it means that the Volunteer must take vacation with only a verbal promise of reimbursed time, and no compensation for expenses. If a country administrator later refuses to reimburse the Volunteer's vacation days, the Volunteer has no recourse to file an appeal. When Volunteers have run out of vacation days and need to travel internationally for their work, they simply can't and don’t. The only other option available to the Volunteer would be to take leave without allowances, which would deduct from a Volunteer’s readjustment allowance for every day of travel taken. This is not a reasonable alternative. As a result, authorization for international job-related travel is extremely difficult to obtain.

Let us examine a recent actual case to demonstrate the problems with this policy. Volunteers in Country A requested job related travel to another Peace Corps country, Country B. The request came when Volunteers in Country A became aware of the possibility of a work partnership with PCVs in Country B, located less than 200 miles away with easy overland connections. The Country B PCVs were specialists in the same type of work, and the opportunity for mutually beneficial collaboration was significant. The Country B PCVs even expressed interest in replicating the work. Everyone involved thought this was a great opportunity to improve upon and spread a project that had already been tested in numerous sites in Country A.

However, the Country Directors separately informed both sets of Volunteers that no job-related leave would be granted. Both sets of Volunteers were told that the other country would need to request the travel and pay for it because their country had no budget for this expense. Moreover, contrary to recent practice, the Volunteers in Country A were not given the alternative of reimbursement of vacation days, and, in the coup de grace, were told that their work was restricted to their specific sites. It was clear that the only alternative available was to pay for the trip themselves and take vacation leave. The Country A Volunteers were disappointed. They had earlier been granted job-related leave to expand their project beyond their specific sites within the country, occasionally in locations nearly as far removed as Country B. The blow to their morale was substantial; fortunately for their project, the pair were not yet out of vacation days.

Ironically, at the same time that their international travel requests were rejected, the Volunteers in Country A received a major international award for their project, based in part on its value and applicability to Peace Corps Volunteers in other countries.

This case exemplifies the problem with current Peace Corps job-related leave policies, those that apply to both in-country and international travel. Even where country managers wish to facilitate Volunteer travel, they are hamstrung by a narrow definition of the "Volunteer's work, regulations concerning per diems and travel payment, and limited budgets. Where country managers are not willing to bend the rules, serious development work can be stifled. Clearly the rules need to be changed.

We propose that the legislation be amended to include a section of job-related leave. This section would provide the following:

* The definition of what constitutes a Volunteer's work should include extension of work opportunities beyond their immediate communities. The definition of leave in Manual Section 220 should be adapted to specifically allow national, regional and international job-related travel for projects of value to the country of origin and/or other Peace Corps countries. Perhaps this expanded definition should apply only to second-year Volunteers whose work has special value beyond their immediate community.

* Volunteers who must undertake international travel for work purposes should also be allowed to use their available vacation leave and the Country Director should be authorized to either reimburse them with vacation days and/or payment of their expenses.

* Volunteer per diem requirements for international job-related travel should no longer be mandatory, nor should payment for transportation costs.

* A special country budget should be granted for job-related Volunteer travel.

* No special medical or security burdens should be placed on countries hosting Volunteers during job-related international travel beyond what it would provide were they visiting as tourists.

3. Job Related Leave to Testify Before or Meet the Congress: Additional issues regarding job-related leave arise in the special context of an invitation to give testimony before the Congress or to meet with Members of Congress or Congressional staff.

In addition to the analysis of job-related leave above, there are additional reasons why the Peace Corps should expand the definition of a "Volunteers' work" when Volunteers are invited to testify before the Congress or meet with Members of Congress and Congressional staff. Leave is routinely granted for in-country meetings and conferences focusing on reforming the programs and policies of the Peace Corps. For example, a Volunteer organized a meeting regarding issues of concern to older Volunteers who were all granted job-related leave to attend. The long-term effectiveness of the Peace Corps requires that Volunteers engage in a continuous process of reforming the agency and its programs.

In addition, mutual support among Volunteers is one of the highest callings and traditions in the Peace Corps. Without it, our service would be considerably more difficult and for some Volunteers, impossible. Indeed, job-related leave is routinely granted so that Volunteers can support each other; peer counseling is the term often used. Testifying or meeting with Congress regarding Peace Corps issues is consistent with this tradition and practice.

Accordingly, to avoid uncertainty about Volunteers obtaining leave, and to protect the jurisdiction of the Congress to oversee the Peace Corps, we recommend that the legislation be amended to provide that job-related leave shall be granted to Volunteers who receive official invitations—such as we received—to appear to testify before or meet with Congressional Committees or their staff. This will ensure that no other Volunteer has to endure the uncertainty and aggravation that we did to secure leave to testify.

We also recommend amending the legislation to require that Peace Corps reimburse Volunteers for the cost of their air and land transportation for such a trip. To preserve our independence and ensure that Peace Corps reimbursement policies would not block our trip, we used personal funds to pay $3300 for our airline tickets to travel to Washington to testify. This amount is over half of the value of one of the readjustment allowances that we've earned during our Peace Corps service.28 We believe that testifying in support of Peace Corps reform and our fellow Volunteers is well worth the expenditure. Few Volunteers, however, have the financial resources to cover the considerable costs of responding to a Congressional invitation. As an accommodation to the Congress, the Peace Corps should be required to cover these costs in the future.

4. Leave Without Allowances (LWOA): Few Volunteers know about a category of leave called "leave without allowance" (LWOA). It's not mentioned on the leave application forms or any other document that's given to Volunteers. The Peace Corps Manual, which Volunteers do not receive, refers to it briefly but it's not mentioned in the Peace Corps Handbook, which they do receive.29 With LWOA, the Peace Corps suspends contributions to the Volunteer's "readjustment allowance" and other benefits (but continues medical support). LWOA is a catch-all category of leave that may be granted at the discretion of the Country Director for any reason whatsoever as long as the leave "will not adversely affect the Volunteer's project unduly or Peace Corps' effectiveness in the host country." It has been granted to Volunteers who run out of vacation leave when they go home to deal with family emergencies. Peace Corps should amend its leave forms and Handbook to mention and define LWOA.

Director Tschetter granted us sufficient LWOA so that we could travel here to testify. The more sensible approach would be to grant job-related leave, as proposed above. But at a minimum, the precedent has been set by the Director that when Volunteers are invited to testify, they will receive sufficient LWOA to enable them to testify.





This is one section from the testimony read into the record on the Peace Corps Volunteer Empowerment Act by Chuck Ludlam and Paula Hirschoff, two RPCVs who are now serving their second tour in Senegal. The rest of the sections can be found by following this link. Their entire report in MS Word format can be downloaded by following this link.




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