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

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6. 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

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

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

9. 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

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

11. 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

12. 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

13. 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

14. 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

15. 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

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

17. 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

18. 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

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

20. 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

21. 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

22. 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

23. 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.

24. 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

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

26. 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

27. 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

28. 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

29. 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

30. 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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