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- Policy Option for the Fund
- General Provisions for the NTF
- Operation of the Training Fund
- Four functions of education
- Pilot Project of Helvetas Kyrgyzstan
- CAMBRIDGE EDUCATION CONSORTIUM
Overview and ApproachThis annex provides a brief overview of the financial mechanisms that might be applied for the National Training Fund. The general approach for introduction of the mechanisms is balancing of demand and supply sides for vocational training in Armenia. According to consultations with the key stakeholders, the Fund should target labor market as its primary area of intervention. The rationale of this idea is an obvious gap between need of economy and services delivered by public institutions. Particularly, Government targets unemployed people as a major segment of policy actions. And according official definition unemployed people are those capable people who: (i) are not employed, (ii) looking for the job, (iii) do not receive pension, (iv) are registered at the Employment service. According to the Law of the Republic of Armenia on “The Budget for the FY 2009”, 249.4 mln AMD are allocated for the vocational training of the people seeking job. 93.4 percent of this amount will be directed to the vocational training of unemployed people, 5.2 percent – for training of disabled, and 1.4 percent – to vocational training of those who receive long-service benefit. This means that a big segment falls out of the trainings available under current system – employed people who want to upgrade their skills or wish to change their job and need training for this, unemployed people who are not registered at the Employment service, people living in rural areas, etc. Taking into account that the major role of the Fund’s activities should be organization of trainings that meets the demand of labor market, the above-mentioned information is an evidence that current model of vocational training does not cover those who are de-facto unemployed, but de-jure are not considered as unemployed.
The resources currently allocated by the Government for training of unemployed – 232.9 mln AMD for 2009, are insufficient to cover actual demand for vocational trainings. On the other hand, the private sector has enough resources to fill this gap but it reluctant to pay more for this service unless it is given an opportunity to participate in the decision-making process. Since the current system of vocational training for labor market does not support the format in which employers might participate to the decision-making, establishment of the VET Fund is recommended as a solution. On the other hand, currently employers are indirectly involved in the training process by hiring unskilled labor. The alternative costs of hiring unskilled labor are minimal wage, payroll tax, and social contributions paid by employer for the period during which this person works with low productivity. In other words, monthly cost of having an apprentice is 8600 AMD, which is paid by business in form income tax and social insurance payments (under assumption that the apprentice provides an output commensurate with the minimal wage). Other incurred costs are those associated with time which more skilled people spend on coaching instead of getting involved in their principal activities.
As an organizational model for the Fund we suggest the model Armenian Deposit Guarantee Fund (ADGF) that has small staff (6 persons) responsible for resource management. Administrative expenses of the ADGF were 19.6 mln AMD in 2008, and for this exercise the administrative budget of the NTF is assumed 20 mln AMD.
This section examines how much money can be raised through current legislation and existing income potential. According to the information released by tax authorities, the top 120 companies of Armenia had turnover (gross income) of at least 4.8 bln AMD in 2008. Article 23 of the Law “On Profit Tax” stipulates that charity donations might be deducted for gross income in the extent up to 0.25 percent of gross income. Under assumption that ¼ of the top 120 companies will donate 0.25 percent of their gross income to the NTF, the budget of the latter will be 360 mln AMD:
In this section we discuss how much money is needed to deliver vocational trainings in amount comparable with the figure of the Employment Service (1370 trainings) at a maximal cost charged by state colleges for 3-months trainings (150000 AMD). In this scenario administrative expenses of the NTF will increase the unit cost of training by 14.6 thousands AMD: 20 mln AMD (administrative budget)1370 (trainings)=14600 AMD (administrative expenses per training) According to the information released by the State Tax Service, the first 1000 large taxpayers paid 100.5 bln AMD as direct taxes (personal income tax and corporate profit tax) in 2008. We assume that among individual companies direct taxes are divided into personal income tax and corporate profit tax in the same proportion as actual receipts of the state budget from these taxes in 2008. According to the Report on Budget Execution for 2008, actual receipts from income tax and profit tax were 53.7 and 86.2 bln AMD respectively. Based on this information we assume that 61.6 percent of direct taxes paid by the first 1000 large taxpayers is attributed to the profit tax. For the purpose of this study we estimate an amount of gross income on the basis of actually paid profit tax. Since the rate of the profit tax is 20 percent we assume that taxable profit is five times higher than actually paid profit tax. In its turn, this estimation of the taxable profit is used as a proxy for gross income. We would like to emphasize that from the point of view resource-building for the Fund this approach is conservative since gross income includes reductions provided by the Law. So, by considering taxable profit and gross income to be the same we come up with minimal estimation of potential of the private sector for creation of the income part of the budget of the Fund. Taking into account that the estimation of the resources necessary for establishment of the Fund is 225.5 mln AMD, within the reductions stipulated by the Law of RA “On Profit Tax” in order to raise enough resources it is necessary that gross income of the companies contributing to the Fund is 90.0 bln AMD (or, which is the same, profit tax is 18 bln AMD). The amount of this size was paid as profit tax by the first 40 large taxpayers (without K-Telecom (VivaCell) and Armenia Telephone Company (Beeline)) in 2008. The K-Telecom and the Armenia Telephone Company are excluded from calculation because due to specifications of the industry where they operate and corporate rules on trainings they are not interested in financing VET system. The break-even point analysis provided below exhibits critical amount of principal beneficiaries and/or unit cost of trainings that may make the establishment of the Fund financially unfeasible. Number of beneficiaries Under the mentioned assumptions the model is quite stable for changes of quantitative variable (number of principal beneficiaries). Particularly, in order to be below break-even point the number of people trained under the programs financed by the Fund should be 981 per year, which 28.4 less as compared to the anticipated level. This figure captures the minimal amount of the people trained, below which the unit operating costs of the Fund will increase total costs to the level higher than 170000 AMD. Unit cost Since the cost of a training provided by the Employment Service is 170000 AMD stability of a price component (under assumption of training of 1370 people) of suggested model is 3.8 percent. We would like to mention that the unit cost of the training delivered by the Employment Service does not include operating costs, while our assumptions for the Fund model include all costs. Budget Costs
Budget benefits
ANNEX 4 - SUMMARY OF STAKEHOLDERS MEETINGS Between 27 April and 30 June 2009 the Team Leader and the Experts had 31 meetings in total with different participants, presented below in the form of a table:
During those 31 meetings only two respondents had reservations regarding the Fund, the rest considered the need for the creation of the Fund as important or very important. The half of the respondents considered the Fund needs to be totally independent from the government, 1/3 finds it more appropriate to have semi-independent status but finds it imperative to have a government representative on the Fund Board. The representatives of the following institutions/organizations have been suggested included on the Fund Board by the respondents:
Below is presented the priority order, mentioned by the respondents: Employers, NGOs,
Trade Unions, Chamber of Commerce and Industry, Colleges, Ministry of Education and Science, Ministry of Social Affairs, Employment Center and others. 1/3 of the respondents find tax exemption as a must for the establishment and development of the Fund. The same number of respondents finds it impossible, grounding it with the reluctance of the government to provide tax advantages for the Fund. Many find it real to have Contractual payments or payments for specific programs and cases. The majority of the respondents think that preparation of specialists in response to the needs of the labour market and employers can become a payment motivation. Only in this case they are ready to make payments to the Fund. The substitution of 0.25% of benevolence provided by the RA Law by 0.5 % is seen as a real option. The respondents also mention the financial support by the European institutions being a crucial furtherance in the initial stage of the Fund activities. As for the structure and composition of the Fund, 8 respondents suggested the National Center for VET Development. They think that NCVETD can implement the Fund Policy, and the Fund Board can work in the same model with NGOs added. They suggest the smaller frame of the same model: 3+3+3+3 as opposed to NCVETD 7+7+7. The preliminary conclusion is that the idea of the creation of the National Training Fund in the Republic of Armenia has matured and will be supported by the stakeholders and other organizations/institutions.
Annex 5.1 – Botswana Annex 5.2 – Czech Republic Annex 5.3 – Ireland Annex 5.4 – Italy Annex 5.5 – Kyrgyzstan Annex 5.6 – South Africa
A Vocational Training Fund (VTF) has been established under the Vocational Training Act of 1998.The objective of this fund is to generate sufficient funds to support skills training by employers and increase skills base at the work place. The specific goals of the VTF are to:
2. Board of Directors The Act stipulates that:
Section 10 (1) of the Act empowers the Board to regulate its own procedure. The Board is mandated to meet at least three times in each year for purposes of discharging its functions. Currently the Board has four scheduled meetings in June, September, December and March of each financial year. However should the need arise a special Board meeting can be held. The Board is composed of members consisting of: Chairman (appointed by the Minister); 4 representatives of employers 4 representatives of trade unions 2 representatives of NGO's involved in vocational training 3 persons appointed by the Minister as having particular expertise in vocational training 6 persons representing the Government (from Ministries)
The Board of Directors (BoD) has the following three (3) sub-committees. TENDER COMMITTEE This subcommittee and its broad terms of reference are as follows:
There are 6 members. HUMAN RESOURCES DEVELOPMENT COMMITTEE This subcommittee is mandated to carry out the following:
There are 5 members. FINANCE AND AUDIT COMMITTEE The sub committee has the following broad terms of reference:
There is a full time Chief Executive Officer, who is accountable to the Board of Directors. He is supported by staff organised into 4 departments:-
Employers are legally obliged to pay 0.2% of their turnover into the Vocational Training Fund via the Value Added Tax (VAT) administration system. The VAT authorities are legally obliged to forward all these funds into the National Training Fund. Each company that pays the levy is entitled to claim grants from the Fund for training their staff. Such training must be for a duration of not than less than10 hours and must be approved training under the National Vocational Qualifications System. Training carried out outside the country will also be recognized provided it meets national standards. Companies can claim all the costs of their training annually regardless of how much levy they have paid. Those companies that spend heavily on training their staff will thus be somewhat subsidized by the fund and those who spend very little or nothing on staff training will lose their levy. ANNEX 5.2 – NATIONAL TRAINING FUND – CZECH REPUBLIC
The National Training Fund (NTF) was established in 1994, within the EU PHARE programme for Human Resources Development. It was set up by the Minister of Labour and Social Affairs as an independent foundation, with representatives of the major partners from the field of human resources development on its board of directors. In the years 1994-97, the NTF budget was exclusively covered by PHARE. At present, the NTF is actively seeking further resources. 2. Operating Experiences The NTF is managed by a director and a board of directors (chairman plus 12 members representing 5 Ministries, chambers of commerce, trade unions, industries and NGOs). The aim of the Fund is to contribute to the social and economic change by supporting human resources development and the improvement of management quality in companies and organisations; to contribute to the implementation of lifelong learning by supporting the development of all forms of adult and continuing education; to support the process of European integration. Within the past four years of its existence, the NTF has focused on the following main objectives:
In the short period of its existence, the National Training Fund has become an outstanding central point, in which demands and priorities from the main partners responsible for human resources development in the Czech Republic are considered and implemented. It plays an important role in the process of assimilating the Czech Republic into the European Union and in the development of a learning society. NTF is a co-organiser of the Czech Adult Learners Week (together with the Association of Institutions of AE and the Czech Society for AE). ANNEX 5.3 – NATIONAL TRAINING FUND – IRELAND Background The National Training Fund was established under the National Training Fund Act, 2000, as a dedicated fund to finance a range of schemes aimed at:
The Fund is resourced by a mandatory levy on employers of 0.7% of reckonable earning in respect of “mainstream” employees. This represents approximately 75% of all insured employees. The Fund supports a range of training schemes operated by the Public Employment Service and Economic Regeneration Agencies. The Fund also support new initiatives in the area of lifelong learning. The Fund is operated by the Government (Model A in section 13.1of the Draft Feasibility Study contained in the body of this document)
The Fund has come under increasing criticism from employers for its high levy rate (7%) and the large budget surplus it has accumulated (189 million EUR). There is concern also that the Fund might reduce its funding for upgrading the skills of existing employees in favour of spending more on re-training the growing numbers of unemployed. ANNEX 5.4 – ITALY NATIONAL TRAINING FUND – ITALY 1 Background Until 2000 the National Institute for Social Insurance had the sole control of the funding of VET for post school-age students. Enterprises compulsorily paid 0.3% of their total payroll (full time workers only) to the National Institute. An Act in 2000 allowed the social partners to establish their own sectoral training funding arrangements: this involves the National Institute transferring the 0.3% levy collected from the sector to a fund administered by the social partners (Employers and Trade Unions).
Funds have been set up in a number of sectors including agriculture, manufacturing industry, and SMEs. The procedure necessary to set up sectoral training funds has two steps:
The funds are under the direct control of the Ministry of Labour. They can be used to finance vocational training projects at company, sectoral and territorial level. The fund will cover 100% of the cost of projects in depressed areas and 50% in other areas. National funds can also act at regional or local level through agreement between the social partners. 3. The operation of the funds Each fund has adopted its own set of rules and regulations which governs its functioning. The common objective of the funds is to promote and finance vocational training programmes at company level - for individual enterprises or for groups where there has been an agreement between the social partners to that effect - and at territorial, sectoral and regional levels. The funds may also finance vocational training programmes which involve workers in enterprises operating in more than one region or that are distributed on a national scale. The resources of each fund go to the employees of the participating, fee-paying enterprises. Each fund must place the resources received from the National Institute into separately managed accounts: one to finance the running of the fund itself (fixed at an annual percentage which differs from fund to fund, but which is not more than 8% of the total resources); and one for the financing of the vocational training projects. A director, nominated by the board of directors, is responsible for the functioning of the funds. The applications for funding of vocational training projects must be sent directly to the head office of the fund or through the the relevant employers' or trade union organisations. The projects are evaluated by a technical team set up at the fund, which must check that all the necessary requirements have been respected. The team must also take into consideration the priorities established by the fund and judge whether or not projects should be funded. Once accepted, a project must be approved by the board of directors, which will then grant the requested payment. The cost of the projects financed for each region must be proportional to the payments into the fund from the enterprises in the region in question. However, each fund, while taking into consideration this stipulation, has the possibility to distribute its resources more equally on a national scale. They must take into consideration the economic situation in Italy, which varies greatly from region to region. The Centre and North, which are heavily industrialised and particularly interested in continuing vocational training, contrast considerably with the South, which has a low productive level and relatively little interest in training programmes. The risk is that only the enterprises located in rich regions with a strong interest in vocational training might make use of the resources available. To avoid this eventuality and encourage enterprises from the South to take a more positive approach to vocational training, the funds have established that a percentage of their total resources can be used to reduce this disparity between regions. This percentage varies, depending on the individual fund, from 5% to 20%. ANNEX 5.5 –REGIONAL TRAINING FUNDS – KYRGZSTAN
What is Local Training Governance?
Education has according to the New Public Management theory four main economic functions:
In the Kyrgyz VET, formally the State is the financier, owner and provider of vocational education and training. However, the State increasingly struggles to fulfil all these functions up to the satisfaction of the users. A pure market model, within which all three functions are private, usually only works in urban areas and for trainings with low capital investment such as computer, business administration or language training. Local Training Governance (LTG) seeks to find a compromise between the state and market model by assigning ownership roles to local governance bodies and the financer role to a wide spectrum of financiers. In other words, Local Training Governance can also be described as a “local training fund”.
A NGO has been created to administer a Local Training Governance in 2 regions. It has been registered as a fund according to Kyrgyz legislation under the name of KOJO. Potential members are all sections of the local community who have an interest in vocational education (such as school representatives, farmers and parents, representatives of the local administration) but also the Government as well as the financiers of the fund (such as enterprises, local and national sponsors as well as international donors). The functions of the KOJO are to:
How is Local Training Governance financed?
Several members of the KOJO have not only an ownership but also a financier function (e.g. enterprises, local and national sponsors, donors, Government). Furthermore, the KOJO will require the vocational schools to raise fees from the participants. During the first years of the Local Training Governance, international donors will contribute the lion’s share of the training delivery costs. However, there will be always more than a single financier involved in one LTG arrangement and financiers will work along a pre-defined financing plan with decreasing grant contribution. A financing plan for one school could look as follows:
Where is “Local Training Governance” applied?
As of 2006, AVEP, the Agricultural Vocational Education Project started a pilot project on Local Training Governance in the Issyk-Kul and Chui oblasts. Vocational schools in these oblasts can apply for piloting Local Training Governance by setting up the KOJO and fulfilling minimum conditions for training provision. The LTG-approach will be used for supporting the vocational schools to introduce a modularised training course for young rural adults to become farmer entrepreneurs. The course development is based on the existing 3-years course implemented since 2000. The course will have a duration of 1,5 years and contain a winter course in basic farm management, a summer farm practice with a combined business planning exercise and a winter course with modules tailor-made for the training needs of the participants.
Once Local Training Governance is established in several schools, the locally established KOJOs shall form a national association in order to resume ownership at the central level for course, curriculum and teaching material development as well as for training of trainers and lobbying. The vocational schools as training providers shall gain a tool for promoting and co-financing not only farmers training but also other training to the rural community.
80% of payments by employers is allocated to Sector Education & Training Authorities and 20% is paid into the National Skills Fund. Sector Education & Training Authorities (SETAs) SETAs (there are 27 covering all employment sectors) are required by Law to develop and implement skills plans for their economic sector. They do this by means of:-
SETAs must promote Learner-ships by:-
SETAs membership consists of:-
SETAs funds come from 5 sources:-
National Skills Fund The National Skills Fund supports projects that are not particular to one one of the 27 SETAs. Examples are:-
ANNEX 6 – AVERAGE COST AND NUMBER OF PEOPLE TRAINED PER YEAR TABLE: VET Provision in Armenia
ANNEX 7- SPECIFIC TERMS OF REFERENCE EUROPEAID/ 119860/C/SV/multi LOT N° 9: Education, Employment and Social REQUEST N° 203 505 SPECIFIC TERMS OF REFERENCE Armenia - ENP AP 2007, Sector Support Programme for Support to Poverty Reduction Strategy through Reforms in Vocational Education Training (VET) Feasibility Study on Establishment of Training Fund for VET Skills Development
The Country Strategy Paper for the period 2007-2013 identifies assistance for reforming and upgrading the education system in compliance with EU standards and best practices as a top priority for strengthening democratic development, social stability and economic competitiveness. In 2008 the revised PRSP (PRSP II) enhanced the importance of VET in the education agenda, and high level political support for improved funding for the sub-sector was agreed. The EU has been assisting Armenia in supporting Poverty Reduction Strategy through TACIS AP 2006 Sector Policy Support Programme (SPSP) which included two components, namely education (VET) and social affairs (Childcare). This was a new experience for the Ministry of Education and Science (MoES) and had an objective to strengthen the sub-sector institutional capacity to steer and monitor VET reform, and link it with budgeting and resources management. It should be mentioned that the MoES was initially one of the four pilot Ministries introducing programme budgeting. Support to VET is being continued under ENP AP 2007 which mentions reform measures in the field of vocational education as one of its priorities. This programme is coherent with the sector policy support programme funded under above mentioned AP 2006 and builds on the activities of the Ministry of Education and Science (MoES) in 2007 aimed at strengthening the reform of VET sub-sector. The objective of the current SPSP in VET is to bring its structure and content into compliance with the demand of the labour market. Assistance is provided in form of budgetary support with a total amount of € 15 mln. The €15 mln is disbursed through 3 instalments of an equal amount. Instalments are payable to the Armenian State budget subject to fulfilment of policy conditions and indicators spelled out in Annex 1 (Policy Conditions Matrix) attached to this ToRs. The first fixed tranche of €5 mln, subject to fulfilment of two pre-conditions and signature of Financing Agreement, was paid to the state budget in June 2008. Second variable tranche was paid in February 2009, although reduced due to partial fulfilment of some of the conditions. Armenia developed and approved a VET strategy and law in 2004. There are two key official documents laying down the sub-sector policy: 1) Strategy of Preliminary and Middle specialised VET, 2) VET Modernisation priorities paper and Action Plan (for period 2005-2008). The former is a general statement on basic objectives for reform, including (i) ensuring preparation of qualified specialists, (ii) ensuring the formation of modern individuals and citizens, (iii) ensuring life-long learning. The latter is a more specific policy document and the closest to a sector programme. The paper prioritizes the introduction of competence-based VET standards, modernisation of quality assurance mechanisms and certification, creation of a state non-commercial technical support and quality assurance institute, improvements in cost-efficiency and educational outcomes, and optimisation of VET financing. Employers' contributions to VET financing is widely used in various countries. Models differ in their scope and application; however the most common one is contributions made by employers to a National Fund which then are used for VET sector development/modernization. The purpose of this ToRs is to explore possibilities of establishment of such a structure in Armenia in terms of applicable policy and legislature.
2.1 Global objective The general objective of the assignment is to support the Ministry of Education and Science in identification and formulation of policy options/legal requirements for establishment of a National Training Fund to support VET skills development in Armenia. 2.2 Specific objective(s) (a) Conduct feasibility analysis of skills development financing by means of national training funds made up of contributions from various stakeholders, such as employers and employees (b) Review current policy and legislation and identify policy options/ legislative requirements for establishment of a National VET Fund.
The Consultant should adopt a strategic and comprehensive, integrated and participatory approach to the drafting of the legislation/policy options for establishment of a National Training Fund. The legislation/policy options drafted should seek to establish integrity, relevance and compliance with the policy/legal requirements of Armenia and at the same time represent international best practice in the area of national funds. The Consultant, in collaboration with the Resident TA, will conduct consultations with key stakeholders at the commencement of the consultancy in Armenia. Regular status meetings will be scheduled with the Consultant and the Resident TA. The Consultant is required to carry out the following activities in order to satisfy the objectives stated above:
2.4 Required outputs During the period of the consultancy the Consultant will be expected to produce the following:
Policy options as well as proposals of draft legislation on Establishment of National VET Training Fund have to be submitted to the Ministry of Education and Science and EC by 31 May, 2009. Translation of relevant documents into Armenian shall be foreseen by the Consultant.
Include report writing Expert 1- VET Policy/Team Leader
Specific Professional Experience
Expert 2 – VET Financing Expert
Specific Professional Experience
Expert 3 – VET Legislation Expert
Specific Professional Experience
Indicative starting period of the assignment is end March – beginning April 2009. The Team Leader will provide a total of 30 working days, whereas Experts 2 and 3 - a total of 60 working days each over a total period of 12 calendar months. Main location of the assignment will be Yerevan. However, if needed, missions can be organised during the duration of the assignment all over the country.
The Contractor shall submit reports in English (1 copy each) to the EC Delegation, National Co-ordinating Unit in the Ministry of Economy, Ministry of Education and Science. Submission procedure for the reports is as follows:
Approval of the reports is a sole responsibility of the EC Delegation. 6. ADMINISTRATIVE INFORMATION 6.1. Maximum budget The maximum budget available for this assignment is € 152,000. The budget includes the fees of the experts, international travel costs and per diem. The fees of the experts cover all administrative expenses. The per diem includes intra-city travels so that they are not eligible once more under reimbursable. Inter-city travels are to be foreseen under “Local Travel”. Incurred communication costs, reports production costs shall be covered by the framework contractor. With regard to office rent, translation and interpretation costs, a provision should be made under “reimbursable”. 6.2. Tax and VAT arrangements On the ground of the specific Council Regulations governing the concerned EC external aid programme, VAT and any other local taxes and duties are excluded from the Community financing (Grant of Facilities – Annex 1). Note: This report has been funded by the European Union for the benefit of the Government of Armenia, specifically the Ministry of Education and Science. The views expressed in the report are those of the contractor (Cambridge Education Consortium) and not necessary those of the European Union nor the Government of Armenia 1The VET system comprises State-run institutions; some Trade Unions and major employers; NGOs; private sector training companies – all of whom organise and deliver vocational courses (see Annex 6) 2The Armenian Government acknowledges most the these weaknesses. It expressed its intention to tackle them in decision N51 taken on 18 December 2008 by accepting the Paper “Concept on development of preliminary professional (craftsmanship) and middle professional (vocational) education in the Republic of Armenia “ . 3A number of otherwise supportive stakeholders commented that employers would NOT contribute to a NTF unless its finances were transparent and fair AND it could be demonstrated the funds were being used to improve the levels of skills in demand in the labour market. The Study Team totally agrees with these prerequisites and believes the recommendations in this Study Report will achieve them. 4In drafting these recommendations the Study Team has been persuaded that the Government is opposed to tax breaks as they would form a precedent and impede action against money laundering. However the recommendations take advantage of the law “On Profit Tax” Article 23, which permits enterprises to offset donations (up to a limit of 0.25%of the total tax bill) to registered charities (the NTF would be a registered charity) . 5Information provided by State Tax Service 6Law “On Profit Tax”, article 23 7For the purposes of this table we have used a cost per training place of 170,000 AMD, which is the basic unit cost of training one unemployed person at present. 8Assuming training cost = 170,000 AMD: the basic unit cost of one training place for unemployed trainees 9Using unit training costs of 170,000 AMD as per unemployed training place at present 
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