ETA Financial System Hot Topics October 5, 2015 Presented by: Nancy P. Taylor Accountant, Region 5 EMPLOYMENT AND TRAINING ADMINISTRATION UNITED STATES DEPARTMENT OF LABOR

The Uniform Guidance (UG) Overview: 2 CFR Part 200 The Uniform Guidance is the first consolidation of Federal grant management requirements in many years There are a number of important changes to the Guidance that will impact your grants and how they are managed. There are additional DOL exceptions to the Uniform Guidance - 2 CFR Part 2900 There are many changes in Subpart A – Definitions

Some Required Updates ETA 9130 Reporting OMB Uniform Guidance New requirements Proposed changes OMB Uniform Guidance Implementation When What De minimis rate Requirements Application of UG- For profit

ETA-9130 Reporting Current Reporting Cycles - While the ETA 9130 PRA is out for comment, continue to use the existing ETA-9130 forms Future Reporting Cycles – Once forms are approved by OMB, all pre-existing and new reporting line items must be reported cumulatively. Comment period for the ETA 9130 PRA package closes on October 5, 2015.  Send comments to:   DPRRpubliccomment@DOL.GOV

Reasons for Change Financial reporting requirements for Federal programs prescribed by the Office of Management and Budget (OMB) have changed with the implementation of the Uniform Guidance at 2 CFR Part 200 which went into effect on December 26, 2014, consolidating eight previously applicable Circulars. DOL’s exceptions to the Uniform Guidance are at 2 CFR Part 2900.

Proposed across the board Changes Affects ALL ETA-9130s including the Basic Form

Changes Line item number 4a was renamed Unique Entity Identifier, as prescribed by 2 CFR 200.210. Line item number 7 was renamed Basis of Reporting Instructions are updated to reflect the definition in the Uniform Guidance at 2 CFR 200.34 Expenditures reported on a accrual basis. Recipient Share Section updated to reflect DOL’s exception to the Uniform Guidance at 2 CFR 2900.8 Cost Sharing or Matching. Report matching funds when EXPENDED. Program income Section updated to reflect the Uniform Guidance at 2 CFR 200.305 (b)(5) Payment. Program income must be expended and disbursed before requesting additional grant funds.

Indirect Costs Indirect cost reporting line items have been added. Indirect cost expenses are only to be reported by the non-federal entity receiving direct awards from DOL. Indirect cost expenses are only reported annually.

Removed Line Items ETA attempts to streamline Federal financial reporting by bringing ETA-9130 requirements as close as possible to the already existing SF- 425 report. The following lines have been removed: 10l – Recipient Share of Unliquidated Obligations 10m – Total Recipient Obligations

WIOA Proposed 9130 Form Updates Transition activities from WIA to WIOA must be reported in section 12 (Remarks) of the ETA-9130. A new In-School Youth Funds Expended on Direct Services reporting line item was added to the Statewide Youth 9130 A new reporting line item for Out-of-School Youth Funds Expended on Direct Services A new reporting line item for Work Experience Expenditures was added to the Local Youth 9130

Additional New 9130 Line Items A new Transitional Jobs Expenditures reporting line item was added to the Local Adult, Local Dislocated Worker, and National Dislocated Worker Grants 9130s A new Pay-for-Performance Contract Expenditures reporting line item A new Federal Share of Unliquidated Obligations for Pay-for-Performance Contracts A new Rapid Response Funds Expended on Other Statewide Activities A new Incumbent Worker Training Expenditures

A Couple of ETA Clarifications: Conference Approval ETA has authority to require pass-through entities notify their FPO and seek GO approval if the costs are in excess of $100k. Costs must be reasonable and necessary to the grant.  2 CFR Part 200.432 Pass -through entities should have process to review and approve. Youth- OSY 75% expenditure requirement Does not apply to PY 2014 WIA carryover Applies to PY 2015 WIOA Funds and all allotments moving forward.

A Few Common UG Questions: When is the official implementation date? What are the requirements to apply for the De minimis rate? Who must apply? Who approves the rate? Who has to follow the UG? Does it apply to for profit entities?

When do I need to Implement the UG Requirements? All new grant awards or grant modifications released on or after December 26, 2014 MUST adhere to the Uniform Guidance Options A and B require grant modification A: Formula recipients may request authorization to apply the Uniform Guidance to existing or old grant awards B: Discretionary recipients may request authorization to apply the Uniform Guidance to existing grant awards Selection - Options A and B Submit modification request in writing to your Federal Project Officer Include a list of grants (by grant number) in which the Uniform Guidance will be applicable Selection – Neither Option A nor B Uniform Guidance applies to all new grant awards or funding released on or after December 26, 2014 Previously awarded funds must follow terms of their grant agreement This may mean maintaining two sets of policies and procedures

Grace Period for Procurement Standards Only Effective date for implementation is revised 200.110 Allows a grace period of one fiscal year to implement 200.317 through 200.336 December 19, 2014 Federal Register Provides additional detail

What are the De minimis Rate Requirements? Type of Indirect Cost Rate discussed at 200.414(f) Entity eligible to receive rate: Has costs classified as indirect costs Entity has never received or does not currently have a negotiated indirect cost rate May charge an indirect cost rate of 10% of modified total direct costs (MTDC) Approved by the awarding agency

Does the UG apply to ME? 200.101 Applicability Applies to all recipients of Federal Awards DOL expanded the definition of Non-Federal Entity to include for-profit and foreign entities including foreign governments. In the past, we had to specify coverage for commercial entities – i.e. through WIA and the Single Audit Act. There was no coverage for foreign entities. This was an important inclusion as DOL’s Bureau of International Labor Affairs also issues grants. See 200.69, page 78615 2900.2 Non-Federal Entity Applies to Commercial & Foreign Entities Service Providers and One Stop Operators

Common Monitoring Findings Conflict of Interest Lack of an Approved ICR or CAP Lack of Internal Controls Policies Lack of Budget Controls Excessive Cash on Hand Not Reporting on an Accrual basis

ETA Updates & Resources Updating One Stop Technical Assistance Guide Updating Core Monitoring Guide Est. Spring 2016 Cfo.gov/cofar Second FAQ released for UG Wioa.workforce3one.org Training resources

ETA SMART TRAINING ROUND 2 DECEMBER 2-4, 2015 CHICAGO, IL Next Steps! ETA SMART TRAINING ROUND 2 DECEMBER 2-4, 2015 CHICAGO, IL

Sample Dual Track Training Agenda