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CBO/FBO Initiative: Frequently Asked Questions on Solicitation SGA/DFA PY 05-08

SGA/DFA PY 05-08 (Grants to Grassroots Organizations)
The Employment and Training Administration announced these competitions on March 21, 2006. The agency will post responses to Frequently Asked Questions raised by prospective applicants on this website.

Applicants are encouraged to visit this website frequently as new questions and answers will be posted frequently. All questions will be serially numbered. A notation will appear that signifies date of posting. The agency recommends reading all of the questions and answers.

TOPICS:
ELIGIBILITY

GRASSROOTS
  1. Are current DOL grantees eligible to apply for this solicitation?
    Yes, current DOL grantees and sub awardees may apply for this solicitation if they meet the eligibility requirements of the SGA.

  2. Please clarify the definition of an eligible grassroots organization in these solicitations.
    As noted in the SGA, eligible grassroots organizations must be non-profits which have social services as a major part of their mission; are headquartered in the local community to which they provide these services; and have 10 or fewer full-time equivalent employees or have a total annual operating social services budget of $500,000 or less. The eligible grassroots organization can define in the application the geographic area for which it proposes to provide services. The Department is looking to broaden the participation of small organizations in the nation's workforce development system, and introduce "first-time" working relationships between these organizations and the agencies that serve our jobseekers and employers.

  3. Are non-profit WIBs or One-Stop Career Centers eligible to apply under this solicitation?
    No.

  4. Please advise what items in an organization's budget should and should not be included as part of its "social service budget" in determining whether that budget is within the $500,000 maximum. Specially, should we include as part of our social services budget the salaries of case managers, employment readiness workshop leaders, and after-school program staff, all of whom provide client services?
    All costs related to provision of social services (including salaries and expenses) should be included. If the organization conducts additional activities (e.g. runs a small business), these would not be included in the calculation.

  5. We are a 501(c) (3), not for profit faith based social service organization with a social services budget of more than $500,000. Our organization consists of more than ten staff. However, we have a specific social service program within our organization with a budget under $500,000 and less than 10 full time employees. This program is suitable for the solicitation and we would like to apply for the grant based on this specific social service program. Can we apply for the small grassroots grant based on this specific social service program in our organization?
    No. The organization budget and full time employees (10 individuals) exceeds the eligibility requirements contained in the solicitation. Although you have a social service program in the organization that meets the requirements, you must demonstrate that this program is separate and can stand alone from the organization (i.e. the program has its own Employer Identification Number and 501(c)(3) status) in order to be eligible and apply for this solicitation based on the program. You are certainly encouraged to partner with the existing One-Stop system in your local area or State.

  6. Please clarify for what year the agency's social services budget has to be under $500,000.
    The cost limitation applies to your current budget year.

  7. I was reviewing the Grants for Grassroots Organizations, SGA/DFA PY 05-08, and neither my boss nor I really know who to contact to find out if we even have a One-Stop in our county that would benefit from such funding.
    This information can be found at the following websites:
    http://www.doleta.gov/usworkforce/onestop/onestopmap.cfm or
    http://www.servicelocator.org/ or
    http://www.nawb.org/asp/wibdir.asp for further assistance.

  8. An organization, formed through local churches, receives donated food and products, which it shares with the poor. The annual estimated value of products, etc. is more than $3 million. However, the organization only has one paid staff and an operating budget of about $250,000. Are they eligible as an organization within the parameters of SGA/DFA 05-08?
    The value of donated items (food or otherwise) has no bearing on the organization's operating budget. So long as the total operating social services budget does not exceed the SGA-limited $500,000, the pass through donations would not disqualify the organization from applying.

  9. Our organization was awarded a sub-award through a DOL WIB grant last year and we are still in the grant cycle until the end of September 2006. Are we eligible to apply for one of the grants for Grassroots Faith-Based and Community Based organizations?
    If you meet the eligibility criterion listed in the SGA, your organization would be eligible to apply.

  10. We are a local affiliate of a National Organization with our own Board of Directors, direct control of our funds, a federal EIN number, incorporated in our state, partially funded by the National Affiliate and registered as a charity with our state charities office. We meet all of the eligibility requirements although we have a national headquarters; our local office operates independently and provides social services directly to the community. Are we considered to be headquartered in the local community?
    From your described set of relationships, it appears your organization is an entity that is separate from your National Organization. In this case DOL would consider your organization headquartered in the local community.

  11. What specific commitments do the One-Stop operators need to address in their formal letters?
    The One-Stop operator must demonstrate a firm commitment to create a referral partnership with the organization applying.


SUBGRANTS
  1. Can organizations provide sub awards with this funding?
    Yes, they can, but the sub awards must adhere to the same rules as the eligible applicants regarding organization type and size. DOL expects sub awardees to be selected competitively from among eligible organizations, in accordance with appropriate OMB Circulars. DOL also expects sub awardees to provide appropriate services and be able to achieve the objectives outlined in the grassroots application.

  2. The Regulations at 29 CFR 95.40 Purpose of procurement procedures show the procurement standards that apply to our grant. Our organization and our partners have come together to develop the grant (concept). Do we need to have a competition for our partners? What is left to procure except for equipment?
    The SGA provides:

    Note: Except as specifically provided in this notice, USDOL-ETA's acceptance of a proposal and award of Federal funds to sponsor any program(s) does not provide a waiver of any grant requirements and/or procedures. For example, the OMB Circulars require that an entity's procurement procedures must ensure that all procurement transactions are conducted, as much as practical, to provide open and free competition. If a proposal identifies a specific entity to provide services, the USDOL-ETA's award does not provide the justifications or basis to sole-source the procurement, i.e., avoid competition, unless the activity is regarded as the primary work of an official partner to the application.

    As long as these are all "official" partners from the time of the proposal development, arrangements with the partners for the provision of services under the grant are not subject to the standards for procurement in 29 CFR 95.40. The providers of all other services and goods, including equipment, must be selected in accordance with the standards for procurement in 29 CFR 95.40. The grantee is responsible to ensure all proper procurement practices are followed.


GRASSROOTS ORGANIZATIONS
  1. What is the maximum amount of dollars that can be requested by a grassroots organization?
    The agency expects to award 54 grants. The grant amount for each grassroots organization is expected to range between $50,000 and $75,000. Final award amounts may be negotiated at the discretion of the grant officer. The period of performance is 18 months, beginning July 1, 2006 and ending on December 31, 2007.

  2. Is there a matching requirement?
    No, but DOL encourages the leverage of resources to increase sustainability.

  3. We have been operating out of the church and our home helping the community until we have a building constructed. Do you have to have a building already constructed to apply for this SGA?
    The applicant must have the capability to deliver services as described in its response to the SGA at the time of grant award.

  4. We are currently not affiliated in any way with the One-Stop delivery system. In order to be eligible for this grant, do we need to be part of the One-Stop system?
    You do not need to have a prior relationship with the One-Stop system, but the intent of this SGA is for your organization to develop one. If you do not have a current relationship with the One-Stop, you must develop one to apply for this solicitation. The overall intent of the grant is to foster both new and stronger relationships between the faith-based and community organizations and the One-Stop delivery system in their area. If your organization meets the eligibility criteria in the SGA, you are encouraged to apply.

  5. What is training under WIA?
    Under WIA, eligible adults and dislocated workers receive training services which may include occupational skills training; on-the-job training; skills upgrading; entrepreneurial training; job readiness training; adult education and literacy activities; and, customized training for employers who commit to hiring trained individuals. Eligibility requirements are outlined in the WIA regulations at 20 CFR Part 663.


LEGAL RULES


The following language appears in section III (3) of the Grassroots SGA:

"The U. S. Government is generally prohibited from providing "direct" financial assistance for inherently religious activities. The Grantee may be a faith-based organization or work with and partner with religious institutions; however, "direct" Federal assistance provided under grants with the U.S. Department of Labor may not be used for religious instruction, worship, prayer, proselytizing or other inherently religious activities. 29 CFR Part 2, Subpart D governs the treatment in government programs of religious organizations and religious activities; Grantees and sub-awardees are expected to be aware of and observe the regulations in this subpart."

  1. May a grassroots applicant limit a sub award competition to a subset of preselected organizations, e.g., its existing affiliates?
    No, such a limitation would exclude eligible organizations from the competition. The competition cannot be limited to such a subset but must be open to all eligible organizations. Please see Part V of the SGA for a discussion of eligible applicants and eligible sub grantees.

  2. If a faith-based organization (FBO) receives financial assistance from the federal government to provide services as part of the One-Stop Center system, can the FBO use religion as a criterion for hiring and other employment decisions?
    It depends on the employment position or positions involved. The Workforce Investment Act (WIA) bars recipients of financial assistance under the One-Stop Center system from discriminating on the basis of religion in employment, but only in the administration of, or in connection with, the programs or activities that received the financial assistance. However, FBOs providing TANF-funded workforce development services through the One-Stop Center system may consider religion in its employment decisions for the TANF-funded program. See No. 7 below.

  3. What types of financial assistance will make an FBO subject to the nondiscrimination provisions of WIA?
    Under the law, "financial assistance" includes much more than simply dollars and cents. The term also includes in-kind assistance, such as free or reduced-rate use of federal land or One-Stop property, federal training, or a loan of federal personnel. Also, placement on a State's list of "eligible training providers" will constitute "financial assistance" with regard to the nondiscrimination provisions under the WIA.

  4. If an FBO uses a meeting room to offer free services at a One Stop Center, but receives no other financial assistance from the One-Stop system, may the FBO use religion as a criterion for employment decisions for those services?
    It depends on how often and how extensively the FBO uses the meeting room. If the use is "casual or transient," then the law does not regard the use as "financial assistance," and the FBO may make faith-based employment decisions for the program or activity that provides the services. If the use of the meeting room is more extensive, for instance, it is used once a week every week, then that use is considered "financial assistance," and the FBO may not make employment decisions on the basis of religion for the program or activity that provides the services.

  5. What if a One-Stop Center lists the FBO as a resource? May that FBO continue to hire and promote on a faith basis?
    The answer depends on the type of "listing" involved. Under WIA, each State is required to assemble a list of training providers that are approved to provide services to beneficiaries through Individual Training Accounts (ITAs). In order to be placed and retained on this list, a training provider is required to submit an application and to satisfy specific requirements regarding cost and levels of performance. These providers are known as "eligible providers of training services" or "eligible training providers."
    If an FBO goes through this process, and as a result is placed on the state's list of "eligible training providers," then the FBO may not use religion as a criterion for employment decisions in the administration of, or in connection with, the programs and activities that it provides through the list.
    Other types of listing as a "resource" will not be considered "financial assistance" under WIA, and therefore the FBO will be able to use religion as an employment criterion. For example, if a One-Stop Center assembles a list of outside resources that beneficiaries may consult for assistance and if the One-Stop Center places a particular FBO on that list with or without the FBO's knowledge, that listing will not subject the FBO to WIA's nondiscrimination provisions.

  6. If a faith-based group, previously allowed to hire on a religious basis because it did not get government money, becomes a recipient of WIA financial assistance, will the FBO have legal problems because it made faith-based employment decisions in the past?
    No. The law does not apply retroactively. Therefore, the WIA nondiscrimination provisions will apply only to the hiring and other activities in which a FBO engages after it becomes a recipient under WIA and only to jobs that administer or are connected with the programs and activities that receive the Federal financial assistance.

  7. If a faith-based group is providing TANF-funded workforce development services through the One-Stop Center system, which employment rule governs the FBO - WIA or Charitable Choice? Does it matter if the TANF money is combined with the WIA funds for the One Stop, or the TANF funded service is only delivered at and administered by the One Stop?
    Charitable Choice, which exempts FBOs providing TANF services from the bar on religion-based employment discrimination, will govern. Therefore the FBO may consider religion in its employment decisions for the TANF program. The way the TANF funds are handled does not matter in this specific instance. It may, however, make a difference with regard to how other laws apply to the program or the organization.

  8. If a faith-based group provides WIA-funded training as a vendor of services, and the State procurement law allows faith-based organizations to hire on a religious basis, does the FBO now come under the WIA nondiscrimination rule or not? Does it matter if the funds are delivered via vouchers?
    Yes, the FBO would be subject to the WIA nondiscrimination provisions. A federal statute overrides a state law that conflicts with it. Furthermore, under those provisions, it does not matter whether the financial assistance is delivered through vouchers. The FBO would therefore be barred from using religion as a hiring criterion for the training programs or activities receiving financial assistance under WIA.



APPLICATION AND SUBMISSION INFORMATION

  1. Where can I find the Budget information forms?
    You can find the Budget form (SF424A) at the following link:
    http://www.doleta.gov/sga/forms/form424a.pdf

  2. Where do I get the application for Federal Assistance (SF 424)?
    You can find the application for Federal Assistance (SF424) at the following link:
    http://doleta.gov/sga/forms/SF424V2.pdf

  3. Where can I find copies of the "Survey on Ensuring Equal Opportunity for Applicants"that can be printed?
    You can find Survey on Ensuring Equal Opportunity for Applicants at the following link:
    http://www.doleta.gov/sga/pdf/Final424 Survey-2006-OMB APPROVED-02-10-06.pdf

  4. How many pages are proposals expected to be?
    Please see Part IV of the SGA.

  5. Where can I find the "lessons learned" from previous grants while introducing several "promising practices" introduced by other DOL grantees?
    CFBCI published several reports on best practices. Experiences from the Field: Fostering Workforce Development Partnerships with Faith-Based and Community Organizations, serves as the basis for a new nation-wide effort to encourage partnerships between FBCOs and Workforce Investment Boards called the Touching Lives and Communities Technical Assistance Program (TLC-TAP). Bridging the Gap: Meeting the Challenges of Universal Access Through Faith-Based and Community Partnerships, highlights strategies by 2002 State and Intermediary grantees to help job seekers access services through grassroots faith-based and community organizations. CFBCI also has created Empowering New Partnerships: Faith-Based and Community Initiatives in the Workforce System, which provides an overview of basic strategies for engaging grassroots organizations in the workforce system. Compassion At Work: Promising Practices in Workforce Development, describes effective practices for faith-based and community organizations and provides examples of how our One-Stop Career Centers and faith-based and community organizations can work together.

    Through TLC-TAP, the CFBCI and ETA are creating a peer-to-peer learning network, publishing tool kits and other resource materials and hosting national conference calls on topics related to the initiative. For more resources, please visit the CFBCI website, www.dol.gov/cfbci as well as the TLC-TAP website, www.nawb.org/fbci.

  6. Is the full announcement online? If so, what is the address?
    The full solicitation for grant applications is on line and they can be found at the following links:
    http://www.doleta.gov/sga/sga/SGA-DFA-05-08.pdf
    http://www.grants.gov/search/search.do?mode=VIEW&oppId=8608


BUDGET
  1. How much, if any, of the funds awarded to an individual grantee under these SGAs can be used to cover the costs of salaries?
    There is no specified limit on the amount of grant funds that may be used to pay the costs of salaries for awards made under these SGAs. The cost limitation indicated in the SGA is a 10% limitation on administrative costs pursuant to 20 CFR 667.210(b).

  2. How do I find Code of Federal Regulations at 20CFR 667.210 (b)?
    It should be available in most comprehensive libraries and is available on-line at http://www.gpoaccess.gov/cfr/index.html. "20" refers to Volume 20 of the Code and section 667.210(b) can be found in part 667, which provides WIA administrative rules.

  3. If we secure supplemental funding to help us meet the solicitation's objectives, where do we reflect these resources?
    The supplemental funding should be reflected in the budget narrative and in the technical proposal if needed to address the evaluation criteria. The Department encourages the identification and leveraging of other funds to support system building.


TECHNICAL PROPOSAL (NARRATIVE)
  1. What does the solicitation mean by "complement" the existing services of the One-Stop?
    The grassroots applicant must demonstrate that they have talked with the One-Stop operator and identified how their services can support and augment those of the One-Stop. The applicant must not duplicate the existing services of the One-Stop.


POST-AWARD
  1. Are site visits anticipated?
    Yes. ETA and CFBCI staff (and/or their contractors) will visit each grantee during the performance period.

  2. After an award, will the first check be received by July 1?
    After awards, grantees will receive instructions about drawing down funds from an electronic payments system on or about July 1.

  3. What are the reporting requirements if we are to receive a grant?
    Each grant recipient will be required to submit electronic quarterly narrative progress reports and financial reports. In addition, a final narrative and budget report will be due at the conclusion of the grant.

  4. If we are awarded this grant, must all monies be spent during the grant period of performance of 18 months?
    Yes.

  5. Could the monies be carried over to the next year, if needed?
    The Period of Performance is 18 months for the grassroots SGA.

  6. Will this grant be offered in subsequent years? Will there be a future year of funding to support the Department's investment in this initiative?
    There is no assurance that there will be funding for this initiative in future years.

  7. Where can we find technical assistance for the grant?
    Upon grant award, the Department will outline its technical assistance strategies to the recipients. Several technical assistance and outreach products that support this grant-making initiative have already been developed (or are underway). This information is found in Part VIII of the SGA.

  8. Are there any restrictions on the income of clients to be served? Are there any age or other restrictions on clients served by the partner CBO/FBO agencies using these grant funds (such as 14-21, high risk, dropout, etc)? Our organization focuses on graduating high school students rather than people already in the workforce. Are we eligible to apply under one of these SGAs?
    There are no age or income restrictions for this competition. The purpose of these SGAs is to engage faith-based and community organizations with the local One-Stop delivery system to fill unmet workforce development needs in the community. Proposals that most persuasively address the service criteria reflected in the SGAs will be rated highest. The income and age determinations fit within this "unmet workforce development needs" objective.