2. YouthBuild Webinar Series: Administrative and Financial
May 24, 2019
YouthBuild Webinar Series: Administrative and Financial
Presented By: OGM-DPRR

3. Jenn Smith
YouthBuild Program Director
U.S. Department of Labor

4. Objective #1 Objective #2 Objective #3 Objective #4
Review the emphasized role of internal controls in the administrative requirements of the Uniform Guidance.
Objective #2
Discuss cost principles of the Uniform Guidance and YB allowable costs and cost limitations per WIOA Law, Regulations, and grant agreement.
Objective #3
Define match and leveraged resources; properly value match; and adequately document and report match.
Objective #4
Review common errors and mistakes

5. Please type your answers in the chat window now!
Identify administrative and fiscal areas with which you or your organization need additional assistance
Please type your answers in the chat window now!

6. Chanel Castañeda
Grants Management Specialist
U.S Department of Labor

7. WIOA Law & Regulations for YouthBuild
Sec. 171
WIOA Law
20 CFR 688
WIOA Regulations

8. Uniform Guidance - Applicability
2 CFR 200 and 2 CFR Part 2900 may be found at

9. Compliance: Hierarchy
Program authorizations/statutes
Other applicable Federal statutes
Applicable appropriations
Implementing Regulations
Executive Orders
OMB Circulars, including the Uniform Guidance at 2 CFR part 200 and 2 CFR part 2900
DOL-ETA Directives
Terms and conditions of award

10. Administrative Requirements- Internal Controls
March 26, 2019
Administrative Requirements- Internal Controls

11. E-CFR Uniform Guidance: (https://www. ecfr. gov/cgibin/textidx

12. Increased Emphasis On Internal Controls

13. Effective Management Systems
Effective financial management system includes:

14. Effective Management Systems (Cont.)
Financial systems that provide reliable and current information:

15. Uniform Guidance Requirements For Internal Controls
2 CFR

16. Internal Controls- Policies & Procedures
Commit effective policies and procedures to writing and distribute to ensure that everyone is
doing the right job and doing the job right.

17. What is a Policy? What is a Procedure?
Guidelines that regulates organizational activities; position statement
What
Why
Often require the approval of a governing board, local government council, and/or President or Executive Director
Description of the normal method of handling things; protocols, steps
How
Often have a less formal approval process; may be approved by a manager or unit supervisor

18. Organizational Management and Effective Internal Controls
Well written policies and procedures can help ensure:
Effective management control
Compliance with applicable laws and regulations
Effective and efficient operations
Considered approach
Transparency
Protection
Clear guidance
Staff and subrecipients
Continuing reference

19. Compliance: Requirements
Some laws, regulations and guidelines contain specific requirements for the recipient to have certain written policies and procedures
OMB Uniform Guidance requirements for written policies:
Payments (b)(6), and 305
Allowable costs (b)(7)
Procurement
Competition
Method for evaluation and selection
Compensation
Fringe benefits
Employee relocation costs
Travel costs
Refer to the new CMG at Objective 3.a: Internal Controls for a listing of recommended polices

20. March 26, 2019
Cost Principles

21. E-CFR Uniform Guidance: (https://www. ecfr. gov/cgi-bin/textidx

22. Standards
Factors Affecting Allowability

23. Prior Written Approval

24. Prior Written Approval (cont.)
Prior approval does not exempt grantees from the requirements that purchases reasonable, necessary and allocable
Purchases must be made prior to the last funded year of grant, even with prior approval
Must be approved by Grant Officer
Will be in written form
Before costs are incurred
Items included in the statement of work or budget as awarded does NOT constitute prior approval (2 CFR )

25. Allocable Costs
2 CFR (a) - A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost:

26. Cost Polling Direct Costs Indirect Costs 2 CFR 200.413(a)
Costs that can be identified specifically with a particular final cost objective… or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
Example:
A case manager works exclusively with YB participants
2 CFR (a)
Costs that can be identified specifically with a particular final cost objective… or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
Example:
An accountant works on multiple Federal programs and also completes the accounting for the organization’s private funds

27. Cost Allocation Indirect costs can be charged through an:
Approved Cost Allocation Plan (CAP) (Appendix III- VI to 2 CFR part 200)
Examples of allocation methodologies: using square footage to allocate rent charges, participant headcount to allocate shared program costs
Negotiated Indirect Cost Rate Agreement (NICRA) (Appendix III-VI to 2 CFR part 200)
Received from cognizant Federal agency for indirect costs
If eligible, the de minimis rate (2 CFR (f))
For eligible grant recipients only
Never received an indirect rate
Has indirect costs to charge to a Federal grant

28. If the following conflicted, which has the highest order of precedence/ hierarchy?
DOL’s exception to the Uniform Guidance at 2 CFR
YouthBuild regulations at 20 CFR
TEGL 16-16
Executive Order 9066

29. ABC organization is allowed to purchase the van for its YouthBuild participants because it was contained in the statement of work and the narrative of the SF-424A budget which was incorporated in the grant agreement. In addition, ABC org has received a verbal approval from its FPO.
True
False

30. Costs Specific To YouthBuild
March 26, 2019
Costs Specific To YouthBuild

31. Real Property Under YouthBuild
WIOA Regulations on real property for YB grants: 20 CFR
Rehabilitation of existing structures for use by homeless individuals and families or low-income families or for use as transitional housing;
Construction of buildings for use by homeless individuals and families or low-income families or for use as transitional housing;
Construction or rehabilitation of community or other public facilities, however only 15% of the grant award is allowable for such construction and rehabilitation (see 20 CFR (b))
The purchase cost of buildings used solely for training purposes is allowable.
The allowable amount is determined based on the proportionate share of the purchase costs related to direct training.

32. Real Property Under YouthBuild (cont.)
All housing activities must comply with:
Current and future Federal, State, and local Fair Housing laws
The following costs are unallowable:
Acquisition cost of the land
Brokerage fees
Inspection fees
Title

33. Property & Construction Costs Under YouthBuild
The costs for acquisition of buildings are allowable with prior Grant Officer approval and only under the following conditions:
The purchase cost of buildings used solely for training purposes;
For buildings used for training and other purposes, the allowable amount is determined
Based on the proportionate share of the purchase cost related to direct training.
Although construction costs are not normally permitted in ETA-funded grants, and are specifically prohibited in the WIOA regulations at 20 CFR , due to the nature of a YB grant
Requires that certain construction costs are essential to the mission of the program
Allowable for YB grants
Further information in TEGL 5-10, Change 1

34. Construction Costs Under YouthBuild
The following costs are allowable to the extent allocable to training YB participants:
Trainees’ tools and clothing including personal protective equipment
On-site trainee supervisors
Construction management
Relocation of buildings
Architecture fees
When making the distinction between allowable and unallowable costs, YB grantees need to consider:
Is the activity and associated costs directly related to participant training

35. Participant Costs Under YouthBuild
Allowable participant costs include (WIOA Regulation - 20 CFR ):
The costs of payments to participants engaged in eligible work-related YouthBuild activities
The costs of needs-based payments
The costs of supportive services
The cost of providing additional benefits to participants or individuals who have exited the program and are receiving follow-up services, which may include:
Tuition assistance for obtaining college credits
Scholarships to registered apprenticeship or technical education program
Employer – or Government-sponsored health program

36. Incentive Payments Under YouthBuild
Grant recipient are permitted to provide incentive payments to youth participants for recognition and achievement directly tied to training activities and work experience
Grant recipients must tie the incentive payments to the goals outlined by the grant program
Goals must be outlined in writing prior to starting the grant
Prior to providing incentive payments, the organization must have written polices and procedures in place governing the awarding of incentives
Must comply with the requirements in the Uniform Guidance

37. Wages, Stipends, or Benefits Under YouthBuild
Provisions of wages, stipends, or benefits to participants in program are allowable
WIOA Law sec. 171(c)(2) – grantees may provide wage or stipends for work experiences (must have written policies)
Compensate youth at the same rates (including periodic increases) as similar trainees or employees in the construction fields, and rates must accord with all applicable laws
YB participants are subject to Davis-Bacon Act labor standards. The Davis-Bacon prevailing wage requirements apply to hours worked on the site of the work
Allowances, earnings, and payments to individuals participating in programs under title I of WIOA are not considered as income for purposes of determining eligibility

38. Wages, Stipends, or Benefits Under YouthBuild (cont.)
Understanding the difference between using stipend or wage as the payment type has specific implication in relationship to the IRS deductions
Wages – indication that participant is paid through a payroll system and subject to applicable taxes to the agency and participant
A W-4 form must be completed and a W-2 form will be issued to the participant
When a wage is paid the program usually provides WC insurance for the participant
Stipends – a payment of a living allowance for training or learning experience
Highly advise to get an IRS determination (SS-8 form) to declare that participants are NOT employees
The grantee is not responsible for SS taxes nor any payroll withholdings
Not paid through the payroll system
A 1099 MISC will be issued to the participant

39. Other Allowable Costs/ Activities Under YouthBuild
Counseling services and related activities, such as:
Comprehensive guidance and counseling on:
Drug and alcohol abuse
Referrals to mental health services
Referrals to victim services
Mental toughness (TEGL 14-09)
Unallowable costs: rope courses, travel costs or speaker fees
Allowable: recruitment and eligibility determination
Supportive services and needs-based payments necessary to enable individuals to participate in the program
To provide needs-based payments, grantee must have a written policy with the following:
Establishes participant eligibility for such payments
Establishes the amounts to be provided
Describes the required documentation and criteria for payments
Applies consistently to all program participants

40. YouthBuild Cost Limitations
WIOA sec.171(c)(2)(C)(i) - WIOA requires an increase in the maximum percentage of funds that may be used for supervision and training of participants on the rehabilitation of community and other public use facilities from 10% to 15%
Salary & Bonus Limitations – no grant funds may be used by a recipient or subrecipient of such funds to pay the salary and bonuses of an individual, either as direct costs or indirect costs, at a rate in excess of Executive Level II
Public Law and TEGL 5-06
Does not include contractors
Consultant fees are capped at $710 per day (refer to current grant’s Terms and Conditions)

41. YouthBuild Cost Limitation (cont.)
20 CFR (a) - Administrative costs for programs operated under YouthBuild are limited to 10% of the grant award (previously 15% of grant award)
Functions and activities that are administrative costs are outlined in 20 CFR WIOA Regulations.
WIOA Law sec. (3)(1) defines administrative costs as: expenditures incurred by State boards and local boards, direct recipients, local grant recipients, local fiscal agents or local grant subrecipients, and one-stop operators in the performance of administrative functions and in carrying out activities under title I that are not related to the direct provision of workforce investment services (including services to participants and employers).
Such costs include both personnel and non-personnel costs and both direct and indirect costs.

42. YouthBuild Cost Limitations (cont.)
20 CFR – What WIOA title I functions and activities constitute the costs of administration subject to the administrative cost limitation?
WIOA Admin vs Program Costs vs Indirect Desk Aid
Can be found on the Grants Application and Management community page:
dmanagement.workforceg ps.org/

43. Infrastructure Costs
Requirements for the sharing and allocating infrastructure costs may be found at:
WIOA sec. 121(h)
WIOA Joint Final Rule – 20 CFR –
Uniform Guidance
2 CFR part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: Final Rule
2 CFR part 2900: OMB approved exceptions for DOL
Guidance & Specific TA:
TEGL 17-16: Infrastructure Funding of the One-Stop Delivery Systems
WIOA Wednesdays Webinar – Infrastructure Funding parts I, II, and III on WFGPS
Sample MOU and Infrastructure Costs Toolkit: _Infrastructure_Costs_Toolkit

44. Infrastructure Costs (cont.)
WIOA makes improvements to the public workforce system including a requirement that partners dedicate funding for allowable infrastructure and additional costs that are allocable to the partner and in proportion to the partner’s use and relative benefit received by the partner program.
Infrastructure costs: are non-personnel costs necessary for the general operation of the one-stop center (WIOA sec. 121(h)(4) and 20 CFR )
One-Stop partners: are entities that carry out the participating programs in a Local Area.
Required partners – under WIOA, YB grantees are required partners in the one-stop centers
Additional partners

45. Infrastructure Costs (cont.)
Required One-Stop Partners
WIOA sec. 121(b)(1)(B) and 20 CFR

46. Infrastructure Costs (cont.)
Required Role of the One-Stop Partners (WIOA sec. 121(b)(1)(A)):
Provide access to program services and activities through the one-stop delivery system
Participate in the operation of the One-Stop system
Enter into a local MOU with the Local WDB relating to the operation of the one-stop system, which includes the IFA
Provide representation on the State board in accordance with the specific programmatic requirements of WIOA
Financially contribute to the operations of the one-stop delivery system including contributing towards infrastructure costs (WIOA sec. 121(b)(1)(A)(ii) and 20 CFR (c))
All partner contributions must:
Be proportionate to the relative benefits received,
Adhere to the partner program’s federal authorizing statute, and
Adhere to the Federal cost principles requiring that costs are reasonable, necessary, and allocable.

47. Infrastructure Costs (cont.)
Proportionate Use
For the purpose of infrastructure funding, proportionate use refers to, among other things, a partner program contributing its fair share of the costs of proportionate to:
An allocation base consistent with the Uniform Guidance
Relative Benefit
When considering proportionate share, the determination of relative benefit received from participating in the One-Stop delivery system is another step in the allocation process

48. March 26, 2019
Match/ Cost-Sharing

49. Uniform Guidance- Administrative Requirements

50. Match vs. Other Leveraged Resources
Match (Cost-Sharing)
Other Leveraged Resources
Required by statute, FOA, or grant agreement
YouthBuild: 25% of Grant Award amount
Contribute to the objective of the ETA grant
Federal
Recipient Share
YouthBuild: Anything above 25% of Grant Award amount

51. What Is Match? Cost-sharing or matching (2 CFR 200.29)
The portion of project costs not paid by Federal funds (unless otherwise authorized by Federal statute)
See also – 2 CFR (Cost-Sharing or matching)
Additional non-Federal funds expended to support grant objectives
When required by statute or the FOA, as a condition of funding
Must be spent on allowable grant activities

52. Basic Criteria For Match
2 CFR (b)

53. Basic Criteria For Match (cont.)
2 CFR (b)

54. Basic Criteria For Match (cont.)
Costs that are not allowable to a grant cannot be used to fulfill a match requirement.
Like Federal costs, match must met ALL seven factors for allowable grant costs under 2 CFR (a-g):
Necessary and reasonable
Conform to any limitations or exclusions
Consistent with policies and procedures
Consistent treatment
In accordance with GAAP
Not included as a cost or used to meet cost-sharing or matching of any other Federally–financed program
Adequately documented

55. Basic Criteria For Match (cont.)
DOL exception at 2 CFR

56. Match- Use of ETA Funds and Other Federal Funds
TEGL 05-10, Change 1
2 CFR (b)(5) states:
Matching funds cannot be funds paid by the Federal government under another Federal award
Except for where the Federal statute authorizing the program “specifically provides” that the program’s funds can be applied to matching requirements of other Federal programs
WIOA, YouthBuild’s authorizing statute, does not provide for YouthBuild funds to be applied to matching requirements of other Federal programs

57. Match- Use of ETA Funds and Other Federal Funds (cont.)
TEGL 05-10, Change 1
For these programs which are not administered through ETA
Grant recipients’ responsibility to consult with that Federal agency
And obtain the necessary documentation to support the recipient’s use of funds towards meeting the YouthBuild match requirement
ETA is unable to provide guidance or technical assistance on other Federal agencies’ programs or the use of their funds

58. Two Types of Match Expenditures
Non-Federal cash expenditures
In-kind contributions
Funds or services provided and paid for by recipient or subrecipient form non- Federal funds
Payment for services that are allowable under the grant
3rd party cash contributions to recipient that are spent by the recipient on allowable costs
Products, space, or services provided by a third-party organization and not paid for by recipient or subrecipient

59. Match Examples

60. Match Examples (cont.)

61. In-Kind Contribution Examples

62. Valuation Standards For Match
Uniform Guidance narrowed and strengthened valuation standards
Donated real and personal property, supplies, etc.
Fair market value at time of donation
Appraisal required for donated buildings and space use
2 CFR and

63. Valuation of In-Kind Contributions

64. Valuation of In-Kind Contributions (cont.)

65. Valuation of In-Kind Contributions (cont.)
Can only allocate match expenditures to what is beneficial to the YouthBuild grant
For shared or indirect match expenditures, must allocate the relative benefit to the YouthBuild grant
Example: A brand new van was donated to a local YouthBuild program by a car dealership. The van is used is the following manner during a work week:
2x a week transports senior citizens (40%)
2x a week transports YouthBuild participants (40%)
1x a week for personal business use (20%)
The match value to the YouthBuild program would be 40% of the fair market value of the van at the time of donation.

66. Documentation

67. Summary of YouthBuild Provisions
YouthBuild 2018 ETA-18-04:
Must provide new cash or in-kind resource as match during the grant period equivalent to exactly 25% of the total Federal share of costs.
To be allowable as part of match, an expenditure must be an allowable charge for Federal grant funds and considered necessary and reasonable to accomplish the project or program objectives. If the cost would not be allowable as a grant-funded charge, then DOL cannot count it toward the applicant’s matching funds.
DOL encourages additional cost sharing above 25% to be committed leveraged resources:
May use to cover costs or materials not otherwise allowable as a charge to grant funds
Must count and document as leveraged resources any chase or in- kind contributions beyond 25% of the grant award amount required as matching funds
From a variety of sources: public sector, non-profits, private sector, investors, and philanthropic communities

68. Can YouthBuild funds be applied to the matching requirements of an AmeriCorps grant? Note that AmeriCorps grants also have a match requirement and these funds originate from the Corporation for National and Community Service.
True
False

69. March 26, 2019
Leveraged Resources

70. What Are Leveraged Resources?

71. Examples of Leveraged Resources?
Note: Valuation of leveraged resources follows same requirements as match

72. Summary of YouthBuild Provisions
YouthBuild 2018 FOA
Must provide new cash or in-kind resources as match during the grant period equivalent to exactly 25% of the total Federal share of costs
Neither prior investments nor Federal resources may be counted towards the matching funds threshold, including funds that were originally provided through Federal funding
DOL encourages additional cost sharing above 25% to be committed as leveraged resources
Cover costs or materials that are not allowable under YouthBuild grant
Must count, document, and report

73. Closeout

74. Financial Reporting Standards
March 26, 2019
Financial Reporting Standards
For Match & Leveraged Resources

75. Sections Of The ETA-9130 Report
Basic Information (Sections 1-9)
Federal Cash Section (10a-10c)
Federal Expenditures (10d–10i)
Recipient Share (10j-10l)
Program Income (10m-10o)
Additional Expenditure Data Required (Section 11)
Remarks (Section 12)
Indirect Expenditures (Section 13) – FINAL only

76. Reporting On ETA-9130 Form Match and non-federal leveraged resources
Report in Recipient Share section (lines 10j through 10l)
Federal leveraged resources
Report on line item 11a (Other Federal Funds Expended)

77. Reporting Match & Leveraged Resources
DOL exception 2 CFR
Grant recipients can only record match expenditures when expended, not received
Grantee must account for funds used for cost-sharing within their accounting systems as the funds are expended

78. ETA 9130: Recipient Share Section
Total Recipient Share Required
10j
Total match requirement. It will be listed on the SF-424a (Section A, Column F “Non-Federal”
If no match requirement = 0
Recipient Share of Expenditures
10k
Any non-Federal funds expended by the grantee for grant related expenditures
Must be allowable costs and would have otherwise been paid out using grant funds
Includes both match and non-Federal leveraged resources
Remaining Recipient Share to be Provided
10l
Sum of line items 10j (Total Recipient Share Required) less 10k (Recipient Share of Expenditures)
Auto-calculated

79. Quarterly Narrative Progress Report

80. Common Mistakes By YouthBuild Grant Recipients
March 26, 2019
Common Mistakes By YouthBuild Grant Recipients

81. Common Mistakes

82. Common Mistakes (cont.)

83. Common Mistakes (cont.)

84. Some Do’s and Do Not’s

85. Introducing The New Core Monitoring Guide

86. YouthBuild Community of Practice
WorkforceGPS:
YouthBuild Community of Practice g/
Grants Application and Management Community Page
gement.workforcegps.org/
Uniform Guidance & DOL’s Exceptions
2 CFR 200
bin/retrieveECFR?gp=&SID=7c9cf c917cc8ba9d3be988e29f0af96b& mc=true&n=pt &r=PART&ty =HTML
2 CFR 2900

87. TEGL and Change 1
Match and Allowable Construction and Other Capital Asset Costs for the YB Program
rr_doc.cfm?DOCN=2932
Change 1
rr_doc.cfm?docn=3801
ETA-9130
Form and Instructions
s/financial_reporting.cfm

88. Grants Application and Management Community of Practice on WorkforceGPS

90. New Grantee Orientation
Washington, DC
April 17-19, 2019

91. Jenn Smith Chanel Castañeda YouthBuild Program Director
U.S. Department of Labor
(202)
Chanel Castañeda
Grants Management Specialist
(312)