Grant and Financial Management TAAA-CCCT Funding Restrictions

TAA-CCCT Grants Similar to other federal grants: Uniform Administrative Requirements Federal Cost Principles Grant Agreement Different than other DOL ETA and Education grants: Indirect Cost Rate vs. F&A rate Administrative costs Prohibitions on wages, real property, tuition Supportive Services

Topics for today’s webinar Indirect Costs Definition Indirect Cost Rate Administrative Costs Definitions Cap Distinctions: Indirect costs vs. Admin Costs Salary Cap

Topics cont’d Prohibitions against wages, tuition, and real property Definitions Supportive services TACT Definition WIA definition Allowable costs

Direct Costs Direct costs: any costs that can be directly identified with a specific grant project/program. Direct costs can be either administrative or program costs 5

Indirect Costs Indirect Costs: any costs shared between multiple programs for which a definitive amount can not be directly attributed to a specific grant. Indirect Cost Rate or Cost Allocation Plan May be both Administrative & Program costs 6

Examples: Direct and Indirect Costs Direct costs – Information/Data Collection System costs for a specific grant: Administrative: all costs directly related to financial recording and reporting Program: all costs directly related to performance tracking and reporting Indirect costs – Equipment maintenance and operational costs for an office working with multiple programs Administrative: general office copiers and printers Program: maintenance costs for lab equipment 7

Indirect Cost Rate Applicable to grantees receiving funds from multiple sources Need approved ICR or Cost Allocation Plan First 90 days No ICR or CAP = no reimbursement for indirect costs Division of Cost Determination contacts F&A Rate is the same as an ICR

Indirect Costs vs. F&A F&A costs are defined in 2 CFR 220 Applicable to Educational Institutions only Specific categories for facilities depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operation and maintenance expenses, and library expenses.

Indirect Costs vs. F&A cont’d Specific categories for administration general administration and general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities (including cross allocations from other pools).

ETA Administrative Costs Defined at 20 CFR 667.210(b) and (c) Can be: Personnel Non-personnel Direct Indirect List of specific functions Allocable portion of necessary and reasonable costs NOT related to the direct provision of services NOT the same as Administration costs under F&A HANDOUT

ETA Administrative Costs cont’d General Administrative functions and coordination of functions Accounting Audit resolution Financial and cash management Payroll functions Purchasing Costs of goods and services required for administrative functions Office supplies Rental and maintenance of office space Costs of information systems related to admin functions Personnel Procurement Accounting and payroll Awards to vendors that are solely for the performance of administrative functions

Administrative Costs Limit 10% of total grant award amount

Administrative Costs - Compliance Measured at conclusion of grant period Not a compliance issue during life of grant If exceed 10% at end of grant, costs will be disallowed

Salary Cap - PL 109-234 Applies to All ETA appropriated funds All grants, contract and interagency agreements All funds available on or after June 15, 2006 Limits salary and bonus payments to individuals Implementation guidance in TEGL 5-06 Not to exceed Executive Level II 2011 = $179,700

What is subject to limitation? Covered individuals Anyone receiving wages or bonus payments from subrecipients from ETA appropriations Salaries paid at a specific rate Bonus payments paid to the individual Exclusions Fringe benefits Non-monetary compensation such as a car

Who is covered? Individuals paid by ETA appropriated funds Direct recipients and all subrecipients Direct costs or through an Indirect Cost Rate Vendors are not subject to limitation

Other funding restrictions SGA lists unallowable activities on pg. 9, 21, and 22 Why prohibitions? They may duplicate services, benefits, or stipends provided to workers eligible for assistance under the TAA, Unemployment Insurance, or Workforce Investment Act programs. Grantees may not use grant funds to supplant other funding sources they are currently using to fund existing activities

Tuition, Wages, and Stipends DEFINITIONS Tuition = the fee for instruction at an Institution of Higher Education Wages = compensation for services performed for an employer Stipends = fixed sum of money paid periodically for services or to defray expenses

Participant wages and stipends Payment of wages NOT allowable Includes wages of students in co-operative education programs Registered Apprenticeship Internships Provision of stipends to training participants for the purposes of wage replacement is not allowable Page 9 of SGA

Tuition and Scholarships Use of grant funds to pay the costs of tuition not allowable (pg. 9 of SGA) Scholarships

Supportive Services Student Support Services WIA Supportive Services I.e. career guidance systems Hiring and/or training staff Developing or procuring online systems WIA Supportive Services Childcare Transportation Dependent Care Housing Needs Related payments

Supportive services STUDENT SUPPORT SERVICES ALLOWABLE WIA SUPPORTIVE SERVICES UNALLOWABLE

Real Property PROHIBITED: Purchase of Real Property Construction ALLOWABLE WITH CONDITIONS: Rearrangement and alteration costs (renovations)

What is Rearrangement and Alteration? Minor alterations to facilities to make ready for the grant Also referred to as renovations

Rearragement/Alterations Addressed in 2 CFR 220 Appendix A Section J.40 – Rearrangement and Alteration Costs Cannot impact equity value Prior approval of the Grant Officer required Examples Refitting laboratory – may be allowable depending on SOW Internal reconfiguration of offices- may be allowable depending on SOW HVAC system installation - unallowable

Intellectual Property Government retains: license to use, reproduce and publish Language to be included on products All work developed under grant must be licensed Creative Commons Attribution 3.0 license Notice of license affixed to work

Questions?? 28 28

Preview – next week – 2 sessions Consortium partners and MOUs – Nov. 15 at 4pm Funding mechanisms Implementation Monitoring For Consortium grantees only! Subgrants vs. Subcontracts and how to procure Nov. 16 at 2:00 pm Review of sub grant prohibition Overview of subcontracts and procurement requirements