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Job-Driven (JD) National Emergency Grants (NEGs) Questions and Answers

PLEASE NOTE: This site will be updated regularly as we receive and answer new questions related to JD NEGs. If you have a question that is not answered below, please submit it to onr@dol.gov. However, please be advised that we cannot respond to questions that ask about specific scenarios or specific proposals that may be incorporated into a JD NEG application at this time.
All applications must follow the guidance provided in the JD NEG TEN

Application Questions

Question 1:
Will JD NEG applications be submitted under the category ”regular“ NEG? If not, which category will be used?

Answer:
Yes, JD NEG applications will be submitted as ”regular“ NEGs. Please see the JD NEG User Guide for specific JD NEG application instructions

Question 2:
If the "regular" category is used, how should states reconcile the focus on serving long-term unemployed with the application requirement that where the state is the applicant, independently eligible events (i.e., layoffs of 50 or more) should have occurred within the state during the 120-day period (4 months) preceding the date of application?

Answer:
The application requirements associated with eligible events and the 120 days are not applicable to JD NEGs. Please see Training and Employment Notice (TEN) 29-13 and the JD NEG User Guide for specific JD NEG application instructions.

Question 3:
How should the costs associated with “Employment Tools” and “Partnership Development” be categorized?  Are these “other” costs?

Answer:
Yes, costs associated with employment tools and partnership development should be categorized as “Other” see pages 24 and 27 of the JD NEG User Guide for specific JD NEG application instructions. As a reminder, only 5 percent of the grant award (total at the Grantee and Project Operator Levels) can be used for employment tools. The same 5 percent cap applies to partnership development activities.

Question 4:
On page 8 of the TEN, under JD NEG Awards, there is language indicating that grantee capacity and previous performance may be considered.  To what degree will prior performance be considered for award?  NEG performance? Workforce Investment Act (WIA) Dislocated Worker (DW) Performance?

Answer:
When granting awards, the Department will primarily consider the information that the JD NEG TEN states must be included in the application narrative (this description begins on page 4 of the TEN).However, the Grant Officer reserves the right to review additional information, including an applicant's capacity and previous performance, in order to make awards in the best interest of the Government.

Question 5:
The JD NEG instructions say that the application must be submitted by COB May 27, 2014. Is that midnight?

Answer:
JD NEG applications must be completely submitted through the NEG electronic application system (eSystem) by 11:59:59 pm eastern daylight saving time on May 27, 2014. Technical assistance for the NEG eSystem will not be available after 4:00 pm eastern daylight saving time on May 27, 2014. Applicants are cautioned not to wait until the last minute to submit their application. Applications received after the closing period (11:59:59 pm eastern daylight saving time on May 27, 2014) will be considered non-responsive and will not move forward for the technical panel review.

Question 6:
Are there any details available around the independent evaluation? Will this be a random assignment? Will ETA notify the State?

Answer:
According to the JD NEG TEN, applicants must acknowledge in their application that they understand that ETA may conduct an independent evaluation, and by accepting a JD NEG award, grantees are obligated to participate in an evaluation, should one be conducted. No decisions have been made yet regarding the methodology of a potential evaluation. Grantees will be provided this information as soon as it is available, and as much advanced notice as possible will be provided to grantees with regard to potential data requests and site visits.

Question 7:
Is the State held to the 1.5% administrative cost limit (grantee level)?

Answer:
No. Per page 8 of the JD NEG TEN, up to 10 percent of the award may be used for administrative costs to operate the project at the state and project operator level. The application must indicate how the applicant proposes to distribute this 10 percent between the state and local project operators.

Question 8:
Will this be the same process as used for the regular NEGs?

Answer:
No. Although JD NEG applications will be submitted through the NEG eSystem like all other NEG applications, JD NEG applications will undergo a review by a technical review panel and will be evaluated against the criteria specified in the JD NEG TEN.

Question 9:
Is a Catalog of Federal Domestic Assistance (CFDA) identification number required for this grant?

Answer:
Yes. CFDA numbers are required and are a part of the SF-424 (Application for Federal Assistance). The CFDA identifier for this grant opportunity is 17.277 (Training and Employment Guidance Letter [TEGL] 10-10.)

Question 10:
Question on the NEG User Guide regarding the Planning Form (page 21). I see that OJT is a subset of Training. However, there's a conflict in language. Are the types of OJT exits a subset of Entering Employment at Exit or stand-alone? Second conflict in language - report EEatE in quarter exited AND in any quarter thereafter - but count only once. What does this mean? Shouldn't the count be when entered employment but not before exited?

Answer:
The Entering OJT Employment at Exit and Entering OJT-Related Employment at Exit lines are subsets of the Entering Employment at Exit line, just as the Enrolled in OJT line is a subset of the Enrolled in Training line. As such, the number of participants Entering Employment at Exit in a given quarter cannot be greater than the number of Exits in that same quarter and the sum of the participants Entering OJT Employment at Exit and Entering OJT-Related Employment at Exit cannot be greater than the number of participants Entering Employment at Exit in the quarter. The number of participants Enrolled in Training in a given quarter has to be equal to or greater than the number of participants Enrolled in OJT during that quarter. Individuals shown as Entering Employment at Exit should be counted after they exit, not prior to exit. Therefore, the number of participants Entering Employment at Exit in a given quarter cannot be greater than the number of Exits in that same quarter. A participant should only be counted once as Entering Employment at Exit; the "AND in any quarter thereafter" refers to the fact that the numbers on the Planning Form are cumulative, so if a participant is shown as Entering Employment at Exit in Quarter 4, this same participant should also be shown in the cumulative numbers reported for Quarters 5 and beyond.


Question 11:
What is the rule around submitting/uploading additional, non-requested documents as supplementary information with the JD NEG application submittal in the NEG eSystem? Is such a submittal deemed nonresponsive and therefore grounds for disqualification? If not, will the supplemental material even be considered if it is not required? In this case, it is a list of employers that have committed to providing work-based opportunities to JD NEG participants.

Answer:
JD NEG applicants are encouraged to submit only those materials directly related to the application itself, as applications will be evaluated based upon the responses to the required elements contained in the JD NEG TEN. Although any additional information provided will be considered, applicants are strongly discouraged from submitting supplemental information. However, if an applicant decides to provide supplemental information, they should carefully review it to ensure it doesn't contradict information provided in the application itself, which would result in additional terms and conditions on any grant award


Eligible Participants

Question 1:
Do the individuals served under this grant need to meet the Dislocated Worker eligibility requirements, which include ”unlikely to return to previous industry“ OR are we treating this as a ”significant dislocation event for purposes of one-time NEG assistance“(this is language from page 3 of the TEN). Under the latter scenario, the individual does not need to meet the unlikely to return test, allowing much greater flexibility in terms of who can be served. Please note that on page 4 of the TEN, it indicates that veterans will need to meet the unlikely to return test. The "significant dislocation event" language on page 3 seems to be contradictory to what is stated on page 4 related to veterans, so clarification is needed.

Answer:
Participants served under JD NEGs must meet the criteria of a dislocated worker, including the provision that they are unlikely to return to a previous industry or occupation.

Question 2:
Recently separated veterans ages 18-24 would be prime candidates for this NEG?

Answer:
Yes, as long as they meet all the eligibility criteria. TEGL 22-04 clarified that separating military service members are generally considered to have met the termination component of the WIA definition of a dislocated worker. So long as all other criteria are met (including "unlikely to return to previous industry or occupation"), a recently separated veteran would be an eligible dislocated worker, and therefore an eligible JD NEG participant. Additionally, Veteran's Priority of Service requirements under 20 CFR part 1010 apply to JD NEG projects.

Eligible Applicants

Question 1:
What types of State entities are eligible to apply for these funds? Are State Workforce Investment Boards (WIBs) eligible to apply for JD NEGs or only State Workforce Agencies?

Answer:
There are two types of entities eligible to apply for JD NEGs.

  • The state workforce agency designated by the Governor to administer WIA (one JD NEG application per state)
  • Federally Recognized Indian Tribes

All JD NEG applications must be submitted through the NEG electronic application system (eSystem), which requires that the system user has qualified for and has been provided with a NEG eSystem password, and has access to the NEG eSystem Personal Identification Number (PIN) that was issued to the state's NEG Primary Signatory/Authorized Representative. See page 3 of the JD NEG User Guide

Question 2:
Is Palau eligible? They are currently under a Compact with the US Government and it is my understanding that they will not be receiving WIA funds after Program Year (PY) 2014.

Answer:
If a U.S. territory is currently receiving WIA DW formula funds, then the territory is eligible to apply for a JD NEG. If a U.S. territory is currently receiving WIA DW formula funds, then the territory is eligible to apply for a JD NEG.

Question 3:
As described in the Federal Register, states are reviewed for 70% of "total available" DW formula program funds as a factor in determining fundability. Is this applicable to the JD NEG?

Answer:
No, the normal 70% DW formula funds expenditure threshold to be eligible for NEG funding does not apply to the JD NEG offering.


Service Delivery

Question 1:
Will core services need to be provided with non-NEG funds before a participant can be enrolled in the JD NEG?

Answer:
While the provision of basic core services is something that should be provided by leveraging resources with other programs, JD NEGs also allow for a variety of activities that are typically considered core and intensive services, as discussed in the Job Coaching and Job Matching Models section of the JD NEG TEN. Generally speaking, the use of JD NEG funds for core services should be limited to the provision of additional core services that are necessary to serve the targeted participants. These services should be described in the application narrative, as discussed on page 6 of the TEN.

Question 2:
Can JD NEG funds be used for a NEG that includes a wage-subsidy provision based on the Reemployment Trade Adjustment Assistance (RTAA) model?

Answer:
No, "subsidized wages" under JD NEGs must be a part of a work-based training strategy, such as on-the-job training (OJT). The RTAA model is primarily a wage subsidy, whereas the JD NEG allows for work-based learning models. The RTAA model allowed payments to employed workers without a training requirement; JD NEGs require participation in work-based training, where the extraordinary costs of training are offset by the provision of a "wage subsidy."

Question 3:
For those states that do not currently have the WIA DW OJT waiver, will the 50% OJT limit on employer reimbursement be automatically waived for JD NEG grantees as it was for the OJT and Dislocated Worker Training (DWT) NEGs?

Answer:
Yes. The Innovation and Flexibility section of the JD NEG TEN (page 7) states that the standard terms and conditions that will be included with JD NEG awards will allow for some commonly requested flexibility, including the OJT sliding scale waiver.

Question 4:
Can states co-enroll DWT NEG participants in the JD NEG?

Answer:
While there are no specific provisions that prohibit co-enrollment with the DWT NEG, co-enrollment must not be used to duplicate services or evade policy restrictions, such as the 6 month limit on employer reimbursement for OJTs.

Question 5:
How much of the JD NEG can be used for staffing?

Answer:
There is no specific limitation on staffing. However, all proposals must comply with the requirements in the Use of Funds section of the JD NEG TEN. As JD NEG applications may include strategies that are staff-intensive, such as OJTs and job coaching, reasonable staff costs associated with these activities are permissible and should be identified in the application's narrative, SF-424A and Planning Form. Applicants are reminded that all expenditures must be allocable, allowable, and reasonable in accordance with OMB Circular A-87.

Question 6:
Are Needs-Related Payments allowed with this grant?

Answer:
Generally speaking, NRPs are an allowable cost under JD NEGs. However, NRPs may not be provided to JD NEG participants who are receiving wages based on their enrollment in work-based learning, such as an Apprenticeship or OJT, although they may receive other forms of supportive services.

WIA Section 101 (46) defines "supportive services" as "services such as transportation, child care, dependent care, housing, and needs-related payments that are necessary to enable an individual to participate in the activities authorized by the grant." Policies regarding receipt of supportive services and needs-related payments should generally be consistent with the established policies and procedures of the local board(s) in the area in which the project is to operate, as required in 20 CFR 671.140(c).

Question 7:
What about union fees? Are we allowed to pay for those before, during, or after an apprenticeship if it's needed to gain employment?

Answer:
If union dues are required for the participant to obtain employment or to enter into an apprenticeship, then it is an allowable cost. However, we expect that the participant will cover subsequent union dues after s/he starts receiving a salary.

Question 8:
Are stipends an allowable cost under JD NEGs -- for individuals that have exhausted Unemployment Insurance (UI) and are receiving short-term training during the day and studying for the General Educational Development (GED) certificate at night - no time to work?

Answer:
No, stipends are not allowable. However, supportive services are allowable to the extent that they are administered in accordance with applicable rules and regulations.

Question 9:
Must the Eligible Training Provider List (ETPL) be used for customized training?

Answer:
No, the ETPL does not have to be used for customized training. Consistent with section 122(h) of the WIA, providers of on-the-job training or customized training are not subject to the requirements of the ETPL. Per page 8 of the TEN, "for non-work-based training, project operators must limit the training opportunities provided to training providers listed in their Eligible Training Provider List..." No such provision is made for work-based learning, which includes customized training.

Question 10:
Is stand-alone remedial training or training for a General Educational Development (GED) certificate allowed under the JD NEG grant or must they be done in conjunction with work-based learning activities?

Answer:
Grantees are strongly encouraged to provide these types of training in connection with work-based learning or occupational skills training to help ensure these NEGs are truly job-driven. However, stand-alone remedial training and/or GED training are not prohibited.

Question 11:
What type of core services would be allowable under the JD NEG?

Answer:
Core services allowable under the Workforce Investment Act (WIA) are also allowable under the JD NEGs and are defined in section 134(d)(2) of WIA.

Question 12:
Is the maximum number of On-the-Job Training (OJT) hours for Job-Driven National Emergency Grants (JD NEGs) applicants limited to six calendar months?

Answer:
The parameters associated with Training and Employment Guidance Letter (TEGL) 4-10, notwithstanding the definition of prolonged unemployed, apply to OJT opportunities offered under JD NEGs. TEGL 4-10 states that the maximum OJT period of reimbursement is limited to six months; therefore, this parameter also applies to JD NEGs.

Question 13:
Although the Job-Driven National Emergency Grant (JD NEG) states that a particular emphasis should be placed on dislocated workers who are long term unemployed, does this specifically prohibit eligible dislocated workers who have not reach 27 weeks?

Answer:
Participants eligible to be served with JD NEG funds must be dislocated workers, with a particular emphasis on dislocated workers who are 1) long-term unemployed for at least 27 weeks in aggregate since 12/2007-6/2009, 2) UI recipients that have been profiled as likely to exhaust their benefits and, 3) foreign-trained immigrant workers, who qualify as dislocated workers, and have faced barriers to obtaining employment in their trained field or profession. However, although emphasis on serving dislocated workers that fall into one or more of these three categories is required and that should be the focus of the NEG, this does not mean that all dislocated workers served under the JD NEG must fall into one or more of these categories.

Question 14:
Do JD NEG participants have to be co-enrolled in the Dislocated Worker formula grant?

Answer:
Although leveraging of existing resources is encouraged, co-enrollment is not required under the JD NEG.



Registered Apprenticeship Questions

Question 1:
What is Registered Apprenticeship?

Answer:
Registered Apprenticeship is a proven and structured "earn and learn" model that pairs paid on-the-job learning with related technical classroom instruction in any number of career fields. Registered Apprenticeship offers job seekers immediate employment opportunities that usually pay higher than average wages and offer continued career growth. Apprentices learn highly sought after skill sets and earn portable credentials from the U.S. Department of Labor (which are recognized by the Department of Education and are nationally and often globally recognized), and gain the opportunity to apply their apprenticeship training to two- and four-year college programs. Registered Apprenticeship programs are offered by tens of thousands of employers, employer associations and labor-management organizations that use the model to grow highly-skilled workers trained to meet current industry specifications, ensure workplace safety, and increase productivity.

Question 2:
With a Pre-Apprenticeship program (no wages provided), are stipends allowable during the unpaid part of the training?

Answer:
No, stipends are not allowable. However, supportive services are allowable to the extent that they are administered in accordance with applicable rules and regulations.

Question 3:
How do JD NEG grantees connect with Registered Apprenticeship opportunities?

Answer:
JD NEG grantees can connect with Registered Apprenticeship by contacting their State Apprenticeship Director to obtain information on locally active Registered Apprenticeship programs. A directory of Apprenticeship staff in each State is available at:http://doleta.gov/oa/contactus.cfm.

Question 4:
How does the probationary period for an apprentice entering a Registered Apprenticeship program impact a grantee's performance measures?

Answer:
A probationary period is a time period reasonable in relation to the full apprenticeship term, with full credit given for such period toward completion of apprenticeship, which allows both the apprentice and the employer to evaluate whether the training and occupation are a good fit for both the apprentice and employer. The probationary period cannot exceed 25 percent of the length of the program, or 1 year, whichever is shorter.

Question 5:
What are the benefits to supporting Registered Apprenticeship-related On-the-Job Training (OJT)?

Answer:
Pairing dislocated workers with Registered Apprenticeship sponsors/employers provides a benefit to both the worker and the Registered Apprenticeship sponsor/employer. The worker will receive paid hands-on training, and the employer will receive a highly-trained employee with a Registered Apprenticeship Completion Certificate upon completion of an OJT program. Participating employers will also receive partial reimbursement, to offset the cost of training workers. Note: The parameters (including the appropriate wage rate reimbursement percentage) associated with OJT in Training and Employment Guidance Letters (TEGL) 4-10, and 16-12 apply to any OJT opportunity offered under JD NEGs, notwithstanding the definition of long-term unemployed contained in the JD NEG Training and Employment Notice 29-13.

Similar to WIA-funded customized training models, OJT also offers several operational advantages that may facilitate workforce system and Registered Apprenticeship collaboration. Like providers of customized training, providers of OJT may take advantage of the streamlined eligible training provider requirements outlined at 20 CFR 663.595. In addition, ETA has granted waivers to states to increase their capacity to offer OJT as a talent development strategy for small- and medium-sized businesses. Under this waiver, approved states may reimburse employers’ extraordinary costs of training participants up to 90 percent of the participant’s wage rate for businesses with50 or fewer employees, and up to 75% of the wage rate for employers with 51 – 250 employees. This may provide an attractive incentive for smaller apprenticeship sponsors to partner with the public workforce system in the design and delivery of the OJT component of Registered Apprenticeship. Employers with more than 250 employees are limited to the standard WIA cap of 50 percent. Note: JD NEG recipients do not need to apply for waivers to obtain these flexibilities.

For more information regarding the use of WIA funds to support and leverage Registered Apprenticeship as a training provider, please reference the ETA Guidance materials listed below:

TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 02-07
Leveraging Registered Apprenticeship as a Workforce Development Strategy for the Workforce Investment System

TRAINING AND EMPLOYMENT NOTICE NO. 44-11
Encouraging Enhanced Partnerships and Collaboration between the Workforce Investment System and Registered Apprenticeship Programs

Question 6:
How can JD NEG training strategies support the use of Registered Apprenticeship? What policies are there regarding participant eligibility?

Answer:
Registered Apprenticeship is one of the work-based learning strategies encouraged for JD NEG grantees. Grantees may help incentivize a Registered Apprenticeship partnership with an employer by using JD NEG funds in several ways, including entering into an On-the-Job Training (OJT) contract with an employer to provide reimbursement for a percentage of the wage rate of the participant to help cover the extraordinary costs of providing the training and additional supervision related to the training. JD NEG funds may also cover non-work based training costs such as classroom training / related instruction components of a Registered Apprenticeship. Non-work-based training must be limited to providers on the Eligible Training Provider List.

Note: The parameters (including the appropriate wage rate reimbursement percentage) associated with OJT in Training and Employment Guidance Letters (TEGL) 4-10, and 16-12 apply to any OJT opportunity offered under JD NEGs, notwithstanding the definition of long-term unemployed contained in the JD NEG Training and Employment Notice 29-13.

The full array of allowable activities under the JD NEGs can be used to support JD NEG participants to enroll in Registered Apprenticeship. This would include costs associated with preparation to enter a Registered Apprenticeship (e.g., pre-apprenticeship training, remediation, etc.) Once the JD NEG participant is enrolled in Registered Apprenticeship, which is considered employment, the JD NEG funds can be used to pay for OJT (limited to 6 months) and classroom training, as noted above. Once exited, follow-up services may be provided, as appropriate, in accordance with Section 134 (d)(2)(K) of the Workforce Investment Act.

NOTE: An individual that is already enrolled in Registered Apprenticeship PRIOR TO being determined eligible by for JD NEG services would be considered an incumbent worker and would not meet the dislocated worker participant eligibility requirement to receive JD NEG services.

Question 7:
If an individual enters Registered Apprenticeship, that program may take longer to complete than the life of the JD NEG. How would a participant be counted if they remained in a Registered Apprenticeship after the grant expires?

Answer:
If a JD NEG participant enters Registered Apprenticeship and the grant ends, that participant would be exited from the grant as they are no longer receiving services funded by the JD NEG. It is not necessary to track apprentices through the completion of their apprenticeship program unless they are supported by workforce system resources for the entire duration. For the purpose of tracking and reporting on the Common Performance Measures, entry of UNEMPLOYED participants into Registered Apprenticeship counts as a positive employment outcome for entered employment and should be recorded in the quarter after Exit from JD NEG services which can occur at any point (e.g., after 6 months of OJT reimbursements), provided the participant is still enrolled in Registered Apprenticeship or employed in that quarter.

To illustrate these points:

Illustration 1: Services ending with a Registered Apprenticeship Placement - A JD NEG participant could receive any combination of core, intensive, pre-apprenticeship, training, and supportive services through the NEG leading to placement in a Registered Apprenticeship. Upon entering the Registered Apprenticeship program, the individual could be exited and counted as a positive placement for the Entered Employment Rate.

Illustration 2: Services continuing after placement in a Registered Apprenticeship Program – In many cases, grantees will provide services to JD NEG participants which lead to readiness for a Registered Apprenticeship placement. Once placed into a Registered Apprenticeship, grantees may continue to help aid the individual through supportive services or covering the costs of classroom training. Grantees may also help incentivize a Registered Apprenticeship employer/sponsor’s participation to hire dislocated workers as apprentices by reimbursing the employer/sponsor for a portion of the OJT, per WIA guidelines. The length of the OJT contract (maximum of 6 months for this grant) will likely not cover the entire duration for longer apprenticeships; however, they do help offset the initial extraordinary costs of the training. Classroom training and other supports may also be provided. Once the NEG-funded services (OJT, supportive, classroom, etc.) have ended, the individual would be exited and counted as a positive placement for the Entered Employment Rate. Also only credentials that are earned by an apprentice while they are enrolled in the JD NEG should be tracked. "Where tracking of earned credentials is required, the workforce system [JD NEG grantees] should track the interim credential earned by the apprentice while co-enrolled." (TEGL 02-07).

NOTE: individual that is already enrolled in Registered Apprenticeship PRIOR TO being determined eligible for JD NEG services would be considered an incumbent worker and would not meet the dislocated worker participant eligibility requirement to receive JD NEG services.


Other Questions

Question 1:
Will funding be provided incrementally?

Answer:
No, the full amount of the grant award will be funded by June 30, 2014.

Question 2:
Last year, our state received a Dislocated Worker Training NEG. After the grant was awarded to us, we were required to submit a Project Operating Plan. Will the same be required of the JD NEG grantees?

Answer:
Yes, Project Operating Plans (POPs) are a requirement of all NEG awards, per page 23068 of Federal Register Notice, Vol. 69, No. 81, dated April 27, 2004.

Question 3:
Is the 5% of funds that can be spent on Employment Tools derived from the total award or the "Modified" amount?

Answer:
Up to 5% of the original award amount can be used to develop or purchase employment tools, provided that the new tools are needed to address a need that cannot be met with available state or federal employment tools/on-line resources or to enhance current tools. The supplemental funding of $175,000 may be used for one or more of the three specific infrastructure activities outlined in Attachment A of the Notice of Obligation, one of which relates to employment tools. See language from the attachment below:

Employment Tools-Per Training and Employment Notice No. 29-13, grantees are allowed to use up to 5 percent of the award to develop or purchase various electronic tools to support the program participants. The supplemental funding can be used to assist a proposed Information Technology plan, or update current systems in place. With the supplemental funding, states are expected to pursue opportunities that:

  • Take advantage of the rapid developments in information technology that make it possible to greatly improve the user experience online and to more closely mimic in-person services rather than simple provision of content to read;
  • Promote access to real-time labor market information; and/or
  • Develop tools specifically tailored to the needs of targeted dislocated worker populations with barriers to employment, such as the long-term unemployed and foreign-trained immigrant workers (who qualify as dislocated workers) and have faced barriers to obtaining employment in their trained field or profession.
  • Question 4:
    Are partners or other organizations identified in the grant application exempt from procurement requirements; in other words, what is the difference between a “subrecipient” and a vendor?

    Answer:
    If the entities in question are truly subrecipients of the funds (see Circular No. A-133 section 210 for an explanation of a subrecipient vs. a vendor relationship), then no procurement is needed. However, if the entities are vendors, then procurement is required and states must follow their own procurement procedures even if the entities were mentioned in the grant.

    Question 5:
    Would you provide clarification about the use of the additional funds received and what is available for the system infrastructure activities included in the Notice of Obligation’s Attachment A? For example, is the $175,000 we received in additional funds strictly for the activities in Attachment A and can it be used in addition to the five percent already allowed?

    Answer:
    TEN 28-19 states that grantees may use up to five percent of the base award for employment tools. Grantees may also use up to five percent of the base award for partnership development. In addition to the base award, Grantees received additional funding to be used on one or more of three specific infrastructure activities outlined in Attachment A of the Notice of Obligation provided to Grantees. One of those infrastructure activities relates to employment tools. As a result, a grantee may choose to use the additional funds received and up to five percent of the base award for employment tools as described in TEN 29-13 and Attachment A of the Notice of Obligation.

    Question 6:
    In the TEN 29-13, the term Long-term unemployed is defined as "unemployed for at least 27 weeks in aggregate since the recession of December 2007 – June 2009." The dates are confusing. Can someone who has been unemployed for the past 27 weeks qualify or did they have to be unemployed sometime between December 2007 – June 2009?

    Answer:
    For the purpose of JD NEG, in order to be served as a long-term unemployed participant, the individual must first meet the definition of a dislocated worker and would have to have been unemployed for at least 27 weeks in aggregate during the recession that began in December 2007 or any time after.

    Question 7:
    May an employment or temporary agency be the employer of record for participants in On-the-Job Training (OJT)?

    Answer:
    OJT contracts should not be written with employment brokers such as hiring agencies, temporary placement agencies, or other third party entities. Instead, OJT contracts should be written with the employers who are actually employing participants and assuming the costs and benefits of the OJT. As with the OJT NEGs, JD NEG OJTs are intended to benefit dislocated workers by utilizing employers who are: 1) willing to train participants who are in need of up-skilling and, 2) willing to permanently hire trainees at the end of the training period.