Cost Allocation Webinar August 12, 2016

Overview Title II Logistics Timelines Leadership Expectations Goals Questions Next Steps Logistics Leadership Expectations Background Oregon Principles Methodology

WORKFORCE SYSTEM EXECUTIVE TEAM Karen Humelbaugh, Title I Patrick Crane, Title II Jim Pfarrer- Title III Pete Karpa, Title IV Dan Haun, Self Sufficiency (TANF-SNAP) Soon to add: Commission for the Blind Unemployment Insurance

BACKGROUND Cost Allocation Workgroup Chartered All Governor Required Partners at the State Agency level Title I Title II Title III Title IV Self Sufficiency (TANF-SNAP)

WIA to WIOA Transition WIA WIOA Memorandum of Understanding Resource Sharing Agreement   WIOA One-stop Center Infrastructure Cost Allocation Plan One-stop Center Shared-Services Cost Allocation Plan

MOUs in WIOA WIOA Sec 121 (c) and Joint Rule Subpart C 678.500-510 WIOA Sec 121 (h) and Joint Rule Subpart E 678.700-755 WIOA Sec 121 (i) and Joint Rule Subpart E 678.760   OMB 2 CFR 200 (Uniform Guidance)

MOUs WIOA Sec 121 (c) and Joint Rule Subpart C 678.500-510 Relatively brief, providing broad direction Required elements: Description of the services provided Method of funding services Method of referral between partners Methods to address individuals with barriers Duration of the MOU Assurances of future review and update

Infrastructure Cost Allocation: WIOA Sec 121 (h) and Joint Rule Subpart E 678.700-755 More detailed discussion of infrastructure funding processes, guidance, definitions, limitations Infrastructure defined as “nonpersonnel costs for the general operation of the one-stop center” including Rent Utilities and maintenance Equipment (which may include assistive technology) Technology Common identifier costs

Shared Services Cost Allocation: WIOA Sec 121 (i) and Joint Rule Subpart E 678.760 Relatively brief, providing broad direction Defined as “costs of shared services that are authorized for and may be commonly provided through the one-stop to any individual” such as Initial intake Assessment of needs Appraisal of basic skills Identification of appropriate services to meet needs Referrals to other partners Business services

OMB 2 CFR 200 (Uniform Guidance) All cost sharing for services and infrastructure must be consistent with Uniform Guidance All costs must be “allowable, reasonable, necessary, and allocable to the program” consistent with the Cost Principles in 2 CFR 200

Challenges for Cost Allocation Plans in Oregon Oregon is Unique SEDAF  “All means All” for Titles I and III WIOA requires more partners be included in the MOU

MOU Cost Allocation Plans (CAPs) One-stop Center infrastructure cost allocation plan   One-Stop Center shared-services cost allocation plan

One-Stop Center Infrastructure CAP All Parties to the MOU must contribute to the cost of one-stop center infrastructure Local Negotiations   State Options, if Local Negotiations Fail

Technical Assistance and Future Guidance One-stop Operator procurement One-Stop Operations Cost Allocation   Paying for the One-Stop Delivery System national webinar on September 21 WSET to issue joint Oregon WIOA MOU/Cost Allocation Plan template and guidance

OREGON PRINCIPLES State agency agreement on cost sharing principles: Apply a uniform methodology to the entire workforce system No law breaking Mitigate risk Compliance with the OMB circular Balance cost to benefit received Appropriately build resources for clients Impact to partner budgets as minimal as possible Recognize change will occur so there is no zero impact scenario

I am TI, TIII, TIV or Self Sufficiency Employment & Training YES Service counts at the individualized level will be used as the methodology for all shared costs including infrastructure/facilities NO I am a TII Partner. Shared costs will be taken at the state level prior to grants being distributed. All other partners/programs must use a fair methodology agreed upon locally. It may be service counts, but this is not required.

METHODOLOGY All Basic Career Services are shared and benefit Title I and III Title I Adult and Title I Dislocated Worker treated as one program Individualized Services will be shared in the cost pool All Basic Career Services provided to SNAP 50/50 customers will be direct charged to SNAP 50/50

Title II- Adult Education & Family Literacy Negotiated at the state Title II administration level Grant reduced at the state level prior to distribution Methodology yet to be determined Inclusive conversations with partners and existing providers Funds reserved at HECC Distributed through IAA to OED Credit applied Reconciled

YEAR ONE- 2016 OBJECTIVE Ensure compliance with 2 CFR 200 on current shared costs Apply WIOA infrastructure and other shared costs requirements to our existing comprehensive centers

YEAR TWO- 2017 OBJECTIVE Include infrastructure and other shared costs for other service locations Take lessons learned from the first year and make any improvements and adjustments to our cost-sharing objectives, guidelines ad tools Explore the option to determine how individual services may be weighted as to reflect actual level of effort

YEAR THREE- 2018 OBJECTIVE First year of Oregon’s fully implemented infrastructure and shared costs requirements Assess our initial work, the outcomes and challenges, and further refine expectations

QUESTIONS???

NEXT STEPS Webinar power point, audio and responses to questions will be posted Unanswered questions will be answered and both sent to participants and posted TA available through your person on Workforce System Executive Team