1. Workforce Investment Act Implementation Training i. Welcome! Administration in the New Millennium 2. Who helped? a. Intergovernmental Organizations b. Community-Based Organizations c. Business Community d. State Government e. Local Government f. Federal Partners g. Others 3. Objectives a. Prioritize administrative issues needed to implement WIA 4. Objectives (continued) a. Demonstrate knowledge of new requirements by selecting which costs are administrative, program or not allowable under WIA 5. Objectives (continued) a. Learn about resource sharing / cost allocation options, and an example of what might be contained in an MOU 6. Objectives (continued) a. Identify WIA administrative requirements for the new millennium 7. Today's Topics a. What's new in Administration b. Admin cost -- definition & limits c. Resource sharing d. Reporting e. Appeals f. Q & A 8. What's New in Administration? 9. Administrative Differences i. Funding Formula Changed a. Three funding streams i. Youth ii. Adult iii. Dislocated Workers 10. Separate Funding Streams 11. More Grantee Flexibility a. State reserve funds may be merged i. Up to 15% from each funding stream 12. More Grantee Flexibility (continued) a. States may distribute Adult and Youth funds to local areas using: i. Standard formula method - or - ii. Alternative (discretionary) formula method 13. Standard Allocation Formulas a. Adult funds and Youth funds b. Distribution based on: i. Relative number of unemployed individuals in each local area ii. Relative excess number of unemployed individuals in each local area iii. Relative number of disadvantaged individuals in each local area 14. Alternative Allocation Formulas a. At least 70% - based on standard formula method b. Remaining 30% may be based on factors related to: i. Poverty ii. Unemployment 15. Alternative Allocation Formulas (continued) a. Alternative formulas must be: i. Developed by State Board ii. Included in State Plan (1) Approved by DOL 16. WIA Allowable Cost Requirements a. For most costs - follow Uniform Allowable Cost Requirements of applicable OMB Circulars on cost principles b. Prior approval authority is delegated to the Governor for costs of Youth and Adult / Dislocated Workers 17. Uniform Allowable Cost Requirements a. Governments. . . . . . Circular A-87 b. Non-Profits. . . . . . . .Circular A-122 c. For-Profits. . . . . . . . 48 CFR Part 31 d. Colleges/Univ . . . . . Circular A-21 e. Hospitals. . . . . . . . . .45 CFR Part 74, Appendix E 18. WIA Cost Requirements a. Purchase/construction of real property: i. Generally unallowable b. Renovation costs - based on OMB Circulars 19. WIA Cost Requirements (continued) a. Information Technology Costs i. Only allowable if the hardware and software are Y2K compliant 20. Uniform Administrative Requirements a. Administrative requirements i. 29 CFR Parts 95 and 97 b. Audits c. Debarment & suspension d. Drug-free workplaces e. Lobbying f. Nondiscrimination 21. WIA Admin Requirements a. Nondiscrimination i. Follow 29 CFR Part 34 ii. Part 37 will replace Part 34 22. WIA Admin Requirements (continued) a. WIA procurement procedures may be different from JTPA i. JTPA - State-wide procedural uniformity ii. WIA - Each recipient or subrecipient uses its own procedures (1) Applicable DOL rules depend on the type of entity obtaining the goods or services 23. WIA Admin Requirements (continued) a. Fee for service i. For incumbent workers ii. Income supports programs 24. Administrative Costs 25. Administrative Costs 26. Administrative Costs i. The Definition a. Allocable portion of i. Necessary and allowable costs b. Overall management & admin c. Not related to direct provision of services to participants 27. Admin Cost Limits i. New Limit was Set by Congress in the Act a. Formula programs i. States: 5% of total allotment (1) Part of 15% Statewide reserve ii. Local Areas: 10% of allocation b. National programs i. Specified in grant award 28. Admin Cost Limits i. Administrative funds have no silos 29. Purchase of Hardware & Software a. Must be reported as an admin cost b. Will not count against the admin cost limit when it's to be used for: i. Participant tracking and monitoring ii. Program participant requirements iii. Core services information 30. Costs Incurred by Boards i. Administrative Functions a. Preparing budgets, program plans b. Negotiating MOUs, contracts, purchase orders c. Public relations activities 31. Costs Incurred by Boards i. Administrative Functions a. Developing systems / procedures including information systems b. Types of systems that are administrative i. Procurement systems ii. Personnel systems iii. Accounting systems iv. Payroll systems 32. Costs Incurred by Boards i. Administrative Functions a. Coordinating audit resolution and incident reports b. Administrative services - legal, financial management, accounting c. Overall monitoring of WIA programs 33. General / Admin Costs i. Costs of goods / services needed for admin of WIA: a. Rental / purchase of equipment b. Utilities costs c. Office supplies d. Postage e. Rental / maintenance of office space f. Travel costs when for administration 34. Information Systems i. Program Costs a. Developing information systems and procedures for: i. Tracking / monitoring WIA program, participant & performance requirements ii. Collecting, storing & disseminating information required as Core services b. Operating these same systems 35. One-Stop Operators i. Administrative vs. Program Costs a. Nature of function or activity determines whether costs is: i. Administrative ii. Program 36. Supervisors/Team Leaders a. Immediate supervision of line staff is now a program cost 37. Time Allocation a. Some personnel perform both admin and program functions 38. Contracting a. For specific activity i. May be either admin or program b. To operate all / part of a program i. May be both admin and program 39. Continuous Improvement i. Some Examples a. Training providers i. Program cost b. Accounting system i. Administrative cost 40. Admin Cost Limits i. How Do You Spell Relief? a. More flexibility - no silos b. Program function and purpose i. First-line supervisors ii. Continuous improvement functions iii. Contracts may be all program iv. Hardware and software v. Systems development/operation 41. Practical Exercise i. Work in groups a. Think about the function i. Not who is responsible, but ii. Intended purpose 42. Sharing Resources 43. What's Wrong with this Picture? 44. Resource Sharing a. The partners in the One-Stop develop an MOU i. How services are to be provided ii. How costs of services are funded iii. How operating costs of the One-Stop are funded 45. Resource Sharing (continued) a. The bottom line is Cost Allocation b. How can it be i. Efficient ii. Effective iii. Fair 46. Cost Allocation Plan a. OMB Circulars b. Necessary, reasonable, allocable c. Indirect and direct costs 47. Cost Pools a. Allocated on some basis b. Relative ease c. Consistent treatment d. Documented 48. Traditional Methodology a. Inputs: i. Time sheets ii. Square footage iii. Supplies 49. Activity-Based Costing a. A process that is designed to identify the cost of activities and services and related outputs 50. Activity-Based Management a. A Tool to improve: i. Management ii. Performance iii. Customer satisfaction 51. Activity-Based Management a. Ensure services are at fair cost b. Develop performance-based budgets c. Develop & maintain performance measures d. Focus on continuous improvement 52. Resources a. Salaries $ 4.25 M b. Contracts 2.03 M c. Rent/Utilities .11 M d. Equipment/Supplies .10 M e. Other .21 M f. Total $ 6.70 M 53. Activities a. Entry services $ .50 M b. Enrollment services 1.75 M c. Training 2.90 M d. Placement services .65 M e. Unemployment services .90 M f. Total $ 6.70 M 54. WIA Reporting 55. General Requirements a. Recipients, including State formula grant recipients, must report per DOL instructions b. Subrecipient reporting requirements 56. Financial Reporting i. Financial Status Report (SF-269) a. State reports of financial status for local areas: i. 1 report for EACH funding stream ii. 1 report for administrative costs 57. Financial Reporting i. Financial Status Report (SF-269) a. State reports: i. 1 report for Rapid Response ii. 1 report for 15% reserve 58. Financial Reporting i. Internet Reporting Formats a. Additional Youth elements: i. Out-of-school vs. in-school expenditures ii. Summer employment opportunities b. Additional Adult & Dislocated Worker element: i. Fund transfers 59. Financial Reporting i. Internet Reporting Formats a. Additional local admin element: i. Costs of computer hardware & software (1) Not subject to admin cost limit b. Additional State elements: i. Administration ii. Costs of computer hardware & software (1) Not subject to admin cost limit 60. Financial Reporting i. SF-269 a. Report must include: i. Expenditures ii. Program income b. Stand-in costs c. Due 45 days after the quarter's end 61. Annual Performance Progress Report a. Performance report for: i. Youth ii. Adults iii. Dislocated Workers b. Be timely! 62. Appeals 63. Appeal Issues a. Grievances b. Non-designation c. Terminated training providers d. Controlled substances e. Substantial violations 64. Grievance Appeals a. Federal review of grievance appeals b. Federal decision - within 120 days c. Most grievances - first resolved at the local and State levels 65. Non-Designation of Local Areas a. 30 Day filing requirement b. Conditions required for an appeal c. Process for resolving an appeal 66. Terminated Training Providers a. Required procedures b. Minimum procedural requirements c. NO Federal appeal 67. Controlled Substances a. Due process required b. NO Federal appeal 68. Substantial Violations a. Local area appeals must be filed within 30 days of State decision when: i. Substantial violation of WIA ii. Failure to meet performance standards. 69. Substantial Violations a. Secretary must make a decision i. Within 45 days on violation of the Act ii. 30 days on failure to perform 70. Summary 71. Why Appeals are Important a. Most WIA appeal provisions not in JTPA b. States can protect themselves by specifying appeal procedures in their five year plan 72. Q & A