Procurement Requirements How to spend the Money Allowable Costs & Procurement Requirements July 29th 2pm EST

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Featured Speakers Presenters Moderator Judi Fisher, Division Chief, Office of Grants and Contract Management, Employment and Training Administration Moderator Mike Qualter, Program Manager, Division of Adult Services, Employment and Training Administration

Division of Adult Services Employment and Training Administration Presenter/Moderator Mike Qualter Program Manager Division of Adult Services Employment and Training Administration

Judi Fisher Presenter/Moderator Division Chief Office of Grants and Contract Management, Employment and Training Administration

What are Cost Principles? Set of government-wide rules OMB Circular A-87, A-122, A-21 48 CFR Part 31, 45 CFR Part 74, Appendix E Applicable to all Federal grants Define conditions for charging costs Allowable & unallowable costs Direct & Indirect costs Incorporated by reference Uniform Administrative Requirements Grant Signature page

Many defined in Circulars Allowable Costs Many defined in Circulars Attachment B – Selected items of costs A-87 & A-122 48 CFR 31.205 A-21, Section J Program regulations Allowable/prohibited activities 20 CFR 668.340-350 20 CFR 667.260-268

3 types of Costs If Cost not Treated- Selected Items of Cost Allowable Unallowable Allowable with Conditions If Cost not Treated- Principles of necessary and reasonable apply

Necessary Reasonable Allocable Specific Conditions To achieve GRANT objectives Reasonable Costs in line with market costs Prudent use Allocable For the purpose of the OJT-NEG grant only

If prior approval requirement exists Approval Conditions If prior approval requirement exists BEFORE incurring cost Must be requested in writing Must be approved May exist in grant agreement Don’t assume Approval requests to Grant Officer

The Governor or the Tribe is the Grant Recipient Approval Authority The Governor or the Tribe is the Grant Recipient Requests approval from Grant Officer Equipment (including sub-recipients) Budget realignments Grant modifications Approval of sub-recipient actions Awarding agency maintains responsibility Compliance with own processes

Equipment, supplies & capital assets Generally Allowable Outreach for programs Marketing of programs Equipment, supplies & capital assets Used for training Not for business purposes Procurement Training costs OJT Coupled activities

Employer and participant recruitment Outreach & Marketing Employer and participant recruitment Public relations activities specified in the SOW Provide information on project goals

Advertising or Public Relations? Defined in the Cost Principles A-87 and A-122, Attachment B, Item 1 Advertising is cost of media Limited to staff recruitment, procurement, or specific purposes identified in SOW Public Relations costs broadly defined Includes meetings & costs associated with outreach activities

Rare need for these grants Tangible property, cost of $5,000 or more Equipment Rare need for these grants Require substantial justification Tangible property, cost of $5,000 or more Equipment must be used for training or other allowable activities Requires prior approval of Grant Officer State grantee must concur with and forward sub-recipient requests for approval

Generally Unallowable Economic Development Paid Employee Release Time Lifelong Learning Entertainment Losses Fines & Penalties Contingency Reserves Employer costs

WIA Prohibited Activities Employment Generating Specific exceptions Sectarian Activities Limited by 29 CFR 37.6(f) & Section 181(b) Final regulations issued July 12, 2004 Business relocation Displacement of workers

Additional Restrictions Recovery Act restrictions No OJT positions Gambling establishment, swimming pools, etc. No needs-related payments Supportive services allowable In line with existing policies No entrepreneurial training

Outreach and recruitment Allowable Activities On-the-Job Training Primary activity of the grant Outreach and recruitment Use of intermediaries Relates to both participants and employers Support services Intensive & other training services ESL, other training

Must be the training strategy for every participant Criteria On-the-Job Training Must be the training strategy for every participant Criteria Hire participant Based on an individualized training plan that reflects the results of an individual skills assessment and an analysis of employer requirements Training is conducted in the work setting under the direction of one or more of the employer’s supervisory personnel The employer is paid a reimbursement for the extraordinary cost of the training.

job readiness & pre-vocational skill training ESL & literacy Additional Services Short term services job readiness & pre-vocational skill training ESL & literacy Certification training Must be linked to employer training plan Additional restrictions apply for use of OJT-NEG funding

Additional restrictions All additional services Should be minimal Must be coupled or concurrent activity only Employer commitment Pre-condition of any additional training

Uniform Administrative Requirements specify full & open competition Procurement Uniform Administrative Requirements specify full & open competition Organizational procurement process followed & documented 29 CFR 97.36(i) Methods for procurement Includes non-competitive requirements

Partner Organizations Integral to OJT-NEG effort “Partner” in development of application Example would be the project operator Not a service provider Absence would lead to project failure Limited Exception for Federal requirements only

Activities specified in SOW or Implementation Plan Partner Activities Activities specified in SOW or Implementation Plan Changes in scope of grant “Partner” does not receive preference New activities subject to procurement rules Requires modification to grant

Function as work sites for participants Employers Function as work sites for participants Outside the procurement requirements Employer agreement required Participants and jobs Wage rates Training plans Working conditions

Subject to procurement requirements Examples include Intermediaries Additional services Outreach, recruitment, counseling & support services to targeted population Funded or unfunded Subject to procurement requirements Examples include Local and community organizations Labor unions Chambers of Commerce & related business organizations

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