1. Grant and Financial Management TAAA-CCCT Funding Restrictions

2. TAA-CCCT Grants Similar to other federal grants:
Uniform Administrative Requirements
Federal Cost Principles
Grant Agreement
Different than other DOL ETA and Education grants:
Indirect Cost Rate vs. F&A rate
Administrative costs
Prohibitions on wages, real property, tuition
Supportive Services

3. Topics for today’s webinar
Indirect Costs
Definition
Indirect Cost Rate
Administrative Costs
Definitions
Cap
Distinctions: Indirect costs vs. Admin Costs
Salary Cap

4. Topics cont’d Prohibitions against wages, tuition, and real property
Definitions
Supportive services
TACT Definition
WIA definition
Allowable costs

5. Direct Costs
Direct costs: any costs that can be directly identified with a specific grant project/program.
Direct costs can be either administrative or program costs 5

6. Indirect Costs
Indirect Costs: any costs shared between multiple programs for which a definitive amount can not be directly attributed to a specific grant.
Indirect Cost Rate or Cost Allocation Plan
May be both Administrative & Program costs 6

7. Examples: Direct and Indirect Costs
Direct costs – Information/Data Collection System costs for a specific grant:
Administrative: all costs directly related to financial recording and reporting
Program: all costs directly related to performance tracking and reporting
Indirect costs – Equipment maintenance and operational costs for an office working with multiple programs
Administrative: general office copiers and printers
Program: maintenance costs for lab equipment 7

8. Indirect Cost Rate Applicable to grantees receiving funds
from multiple sources
Need approved ICR or Cost Allocation Plan
First 90 days
No ICR or CAP = no reimbursement for indirect costs
Division of Cost Determination contacts
F&A Rate is the same as an ICR

9. Indirect Costs vs. F&A F&A costs are defined in 2 CFR 220
Applicable to Educational Institutions only
Specific categories for facilities
depreciation and use allowances,
interest on debt associated with certain buildings,
equipment and capital improvements,
operation and maintenance expenses,
and library expenses.

10. Indirect Costs vs. F&A cont’d
Specific categories for administration
general administration and general expenses,
departmental administration,
sponsored projects administration, student administration and services,
and all other types of expenditures not listed specifically under one of the subcategories of Facilities (including cross allocations from other pools).

11. ETA Administrative Costs
Defined at 20 CFR (b) and (c)
Can be:
Personnel
Non-personnel
Direct
Indirect
List of specific functions
Allocable portion of necessary and reasonable costs
NOT related to the direct provision of services
NOT the same as Administration costs under F&A
HANDOUT

12. ETA Administrative Costs cont’d
General Administrative functions and coordination of functions
Accounting
Audit resolution
Financial and cash management
Payroll functions
Purchasing
Costs of goods and services required for administrative functions
Office supplies
Rental and maintenance of office space
Costs of information systems related to admin functions
Personnel
Procurement
Accounting and payroll
Awards to vendors that are solely for the performance of administrative functions

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

14. Administrative Costs - Compliance
Measured at conclusion of grant period
Not a compliance issue during life of grant
If exceed 10% at end of grant, costs will be disallowed

15. Salary Cap - PL 109-234 Applies to
All ETA appropriated funds
All grants, contract and interagency agreements
All funds available on or after June 15, 2006
Limits salary and bonus payments to individuals
Implementation guidance in TEGL 5-06
Not to exceed Executive Level II
2011 = $179,700

16. What is subject to limitation?
Covered individuals
Anyone receiving wages or bonus payments from subrecipients from ETA appropriations
Salaries paid at a specific rate
Bonus payments paid to the individual
Exclusions
Fringe benefits
Non-monetary compensation such as a car

17. Who is covered? Individuals paid by ETA appropriated funds
Direct recipients and all subrecipients
Direct costs or through an Indirect Cost Rate
Vendors are not subject to limitation

18. Other funding restrictions
SGA lists unallowable activities on pg. 9, 21, and 22
Why prohibitions? They may duplicate services, benefits, or stipends provided to workers eligible for assistance under the TAA, Unemployment Insurance, or Workforce Investment Act programs.
Grantees may not use grant funds to supplant other funding sources they are currently using to fund existing activities

19. Tuition, Wages, and Stipends
DEFINITIONS
Tuition = the fee for instruction at an Institution of Higher Education
Wages = compensation for services performed for an employer
Stipends = fixed sum of money paid periodically for services or to defray expenses

20. Participant wages and stipends
Payment of wages NOT allowable
Includes wages of students in co-operative education programs
Registered Apprenticeship
Internships
Provision of stipends to training participants for the purposes of wage replacement is not allowable
Page 9 of SGA

21. Tuition and Scholarships
Use of grant funds to pay the costs of tuition not allowable (pg. 9 of SGA)
Scholarships

22. Supportive Services Student Support Services WIA Supportive Services
I.e. career guidance systems
Hiring and/or training staff
Developing or procuring online systems
WIA Supportive Services
Childcare
Transportation
Dependent Care
Housing
Needs Related payments

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

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

25. What is Rearrangement and Alteration?
Minor alterations to facilities to make ready for the grant
Also referred to as renovations

26. Rearragement/Alterations
Addressed in 2 CFR 220 Appendix A Section J.40 – Rearrangement and Alteration Costs
Cannot impact equity value
Prior approval of the Grant Officer required
Examples
Refitting laboratory – may be allowable depending on SOW
Internal reconfiguration of offices- may be allowable depending on SOW
HVAC system installation - unallowable

27. Intellectual Property
Government retains: license to use, reproduce and publish
Language to be included on products
All work developed under grant must be licensed Creative Commons Attribution 3.0 license
Notice of license affixed to work

28. Questions?? 28 28

29. Preview – next week – 2 sessions
Consortium partners and MOUs –
Nov. 15 at 4pm
Funding mechanisms
Implementation
Monitoring
For Consortium grantees only!
Subgrants vs. Subcontracts and how to procure
Nov. 16 at 2:00 pm
Review of sub grant prohibition
Overview of subcontracts and procurement requirements