1. TAAA-CCCT Grants for FPO’s Refresher Training
For Federal Project Officers
June 25, 2012

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6. 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, tutoring
Supportive Services
Subgrant prohibition
Consortium grants

7. Topics for today’s webinar
Indirect Costs vs. F&A
Indirect Costs vs. Admin Costs
Administrative Cost cap
Intellectual property
Procurement requirements
Equipment

8. Topics cont’d Funding restrictions and unallowable costs
Supportive services
TACT Definition
WIA definition
Allowable costs
Subgrant prohibition
Consortium grants
Cost allocation

9. 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 9

10. 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
For consortiums, each entity needs its own ICR in order to claim indirect costs.

11. 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.

12. 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).

13. ETA Administrative Costs
WIA definition of administrative costs incorporated into TACT grants
Potential areas of confusion for grantees:
Difference between 2 CFR “Administration” and WIA Administrative Costs
Thinking indirect costs and administrative costs are the same
HANDOUTS

14. Administrative Costs Limit
10% of total grant
award amount

15. 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

16. 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

17. Creative Commons 3.0 license
Allows subsequent users to copy, distribute, transmit and adapt the copyrighted work
Requires users to attribute the work in the manner specified by the Grantee.
Notice of the License shall be affixed to the copyrighted work
Also called CC BY

18. Products/Learning Materials
What counts as “work” or “new learning materials”?
Copyrightable works created by grant recipients, consortium members, contractors, and subcontractors
If grants funds are used to create a derivative work from an existing copyrighted work in developing materials for the grant, then the grant work must be licensed under Creative Commons 3.0

19. Procurement Procurement Requirements Procurement Regulations:
Open and free competition
Sole source
Procurement Regulations:
29 CFR Part 95 or Part 97
Procurement standards for partners and subcontracts

20. Equipment 29 CFR 95.2(n) and 29 CFR 95.34
Submitted on behalf of consortium members and subcontractors
Software not considered equipment
Equipment ETO
If over $150,000 per unit, request goes
to National Office GO.

21. Funding Restrictions SGA lists unallowable activities on pg. 10 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

22. 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

23. 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 10 of SGA

24. Tuition, Scholarships and Assessments
Use of grant funds to pay the costs of tuition not allowable (pg. 10 of SGA)
Scholarships – not allowable
Student assessment and testing fees - conditional

25. Tutoring
Use of grant funds to pay the costs of providing tutoring for individual participants is not allowable.
Only benefits individual participants.

26. 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

27. Supportive services STUDENT SUPPORT SERVICES ALLOWABLE
WIA SUPPORTIVE SERVICES
UNALLOWABLE

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

29. Rearrangement/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

30. Subgrant Prohibition
Grantees do not have authority under this program to award sub-grants (pg. 22 of SGA)
Consortium members are not subgrants
May award subcontracts, but must meet definition of subcontract (Attachment A to SGA)
Contents:
General purpose,
Programmatic functions, and
Responsibilities that the grantee gives to the other organization along with grant funds

31. Subgrants vs. Subcontracts
Subgrant: An award of financial assistance in the form of money, made under a grant by a grantee to an eligible subgrantee.
Subcontract: An agreement, purchase order, or any legal instrument issued to a third party the subcontractor, calling for the performance of a defined piece or work or production and/or delivery or specified goods and services.

32. General Purpose Subgrant
To accomplish a public purpose of support or stimulation through the grant, as authorized under statute.
Subcontract
Purpose is to provide supplies and/or services

33. Focus
Subgrant
Carries out one or more major programmatic functions in support of the goals of the grant
Subcontract
Does not support the goals of the grant directly
Provides supplies and/or services that are ancillary or supportive to the operation of the grant

34. Recipient Responsibility
Subgrant
Has responsibility for:
programmatic decision making,
adherence to applicable Federal program compliance requirements,
Is able to determine which participants are eligible to receive Federal financial assistance.
Subcontract
Provides supplies and/or services for use by the prime grantee that are supportive to the operation of the grant.
Subject to procurement regulations, but not programmatic compliance requirements
Does not have decision-making authority pertaining to the grant.

35. Vendors
Contract to provide goods, supplies and/or services as part of normal business operations
Does not directly support goals of grant; ancillary to the operation of the program
Does not have programmatic decision making authority
Not subject to program compliance requirements
Subject to procurement regulations
OMB Circular A-133, Section 210

36. Is it a subcontract? Grantee issues RFP seeking to award contract to:
Assess skills, aptitudes and career interests of participants
Provide career advise and job search assistance
Conduct workshops on resume writing and job interviewing techniques
Provide referrals to services provided by workforce, education or public assistance agencies
Help participants develop individual career plans

37. No…called a subcontract but…
Activities listed are all deliverables under the grant
Program responsibility placed on contractor, not the grantee
BUT
Shift program responsibility to grantee
Procure specific goods or services
Clearly articulate what goods or services vendor is providing the grantee
COULD BECOME A SUBCONTRACT

38. Examples of activities in subcontracts
Hosting meeting of SME’s to assess curriculum needs
May be subcontract provided that:
Vendor is not wholly responsible for performance of grant activities
Vendor does not have authority to make decisions
Vendor provides grantee with defined deliverable (i.e. report)
Oversight provided by grantee
Researching, designing and developing a program/curriculum to allow career pathway for participants to obtain professional certification
As vendor/contractor they design and develop materials but do not make programmatic decisions
Provides grantee defined deliverable
Grantee utilizes these materials to provide career pathway to participants – not contractor

39. Examples continued May be contract provided that:
Hosting and participating in Instructor Certification Training
May be contract provided that:
Contractor is providing training
Training must be done on behalf of the grantee and under grantee’s name
Contractor cannot select or screen training participants or evaluate participates other rating pass/fail grade for course
There is a defined contract deliverable
Creating a common project book to be used by participants
Grantee is procuring a product (project book) that helps to achieve grant deliverable
The product is not the grant deliverable but will be used by grantee to meet its deliverable
Talk about asking for NO opinion – limitations – will not “approve” contract language. In certain cases, if FPO is concerned, will review and let FPO know if we have concerns about whether it’s a subgrant or subcontract.

40. Utilizing the Workforce System
Required to consult with workforce system (SGA, page 7)
May contract with workforce system to provide staff-assisted or customized services such as:
Comprehensive assessment, case management, participant tracking
or job placement
Subgrant prohibition still applies
Program responsibility with grantee
Workforce system cannot produce deliverables on behalf of grantee
In this capacity, workforce system is a vendor delivering contracted services, not a subrecipient.
May not duplicate services provided to same participants through the One Stop or other ETA programs.

41. Utilizing the Workforce System cont’d
Just because it is a state or local area, its not a subgrant or subrecipient – it’s a contract for their services.
Not eligible as grantees
Must not be listed as members of a consortium in consortium agreement

42. Implementing Consortiums
Consortium members are not subrecipients or vendors
Lead institution has award with DOL. They are:
the point of contact with DOL to receive and respond to all inquiries or communications under this SGA and any subsequent grant award;
the entity with the authority to withdraw or draw down funds through PMS
responsible for submitting to all deliverables under the grant, including all technical and financial reports related to the project, regardless of which consortium member performed the work;

43. Implementing Consortiums cont’d
Lead institution is the entity:
4) that may request or agree to a revision or amendment of the grant agreement or modification to the statement of work;
5) with overall responsibility for carrying out the programmatic functions of the grant, as well as for the stewardship of all expenditures under the grant; and
6) responsible for working with DOL to close out the grant.

44. Cost Allocation
Majority of costs will be allowable activities described on Pages 9 and 10 of SGA.
Needs to benefit the grant
Improve grantee’s ability to provide suitable education and training programs for TAA eligible workers
Support college’s general capacity
Clearly identified in grantees SOW
Determine if cost can be charged completely or only a portion

45. Cost Allocation
Costs are TAACCCT program or class centered, not a participant-centered
i.e. not TAACCCT vs. non-TAACCCT participants
Grant pays for:
Hiring/training additional instructors to develop/deliver new curricula
Upgrading classroom supplies for courses supported by the grant
Implementing changes in the time or scheduling of classes
Grant pays for that program or class, or portion thereof, that is created or enhanced by TAACCCT grant.

46. Questions?? 46 46