Presentation to the #ETARegion1 financial directors on Trade funding.

1. Region 1 Boston
#ETARegion1
Financial Directors Meeting
August 2013

2. Presenters
Presenter: Tim Theberge
Title: Regional Trade Coordinator
Organization: Region 1
2#

3. Topics to Cover
3#
• Trade Funding Types
• TAA Funding update
• Allocation Rules per Grant Year
• TAA Allocation Rules in contributing to shared
resources including:
• One Stop Infrastructure
• Electronic Case Management Integration
• Why using funds to support integration
works

4. Trade Funding Types
• TAA = Training, job search, relocation,
case management & related costs
• TRA = Income support benefits
• A/RTAA = Wage insurance payments
# 4

5. TAA Program, Case Management and Admin
How much can I spend for what?
• Be mindful of funding source – must be
an allowable activity under that funding
stream to be charged to the grant
• Citations: Trade Act 235(A)(1)(6); TEGL
22-08 Section G(2) and G(3); TEGL 10-
11; 20 CFR 618
5

6. Funding Status Issues / Recommended Practices
• 3 Year Money
– Different Law = Different Restrictions
– Proper cost allocation
• Expiration and Closeout
– Shifting pots
– Proper cost allocation
# 6

7. Case
Management
Admin
15% above amount provided for training
+
Additional $350,000 for Case Management
Conditions
Maximum 2/3 may be used for Admin
Minimum 1/3 must be used for Case Management and
Related Costs
Training
Job Search &
Relocation
$220 Million
Note:
• Grant Expiration – 09/30/13
• ETA-9130 report for each grant – old form pre-03/31/12
• Reference: TEGL 22-08, TEGL 13-11, 20 CFR 618
7

8. Case
Management
Admin
Job Search &
Relocation
Training
Consolidated Allocation
$575mil. CAP
Conditions
Up to 10% of Consolidated Allocation may be used for
Administration
Not less than 5% of Consolidated Allocation must be used for
Case Management.
Note:
• Grant Expiration – 09/30/14…
• ETA-9130 report for each grant – new form post-03/31/12
• References: TEGL 13-11, TEGL 22-08, 20 CFR 618 8

9. Poll Q: Coordination between participation timing
and grant year
TRUE or FALSE: A participant that enters
the program in FY‟13 must be served
through the FY‟13 grant allocation?
# 9

10. Poll Q: Allocation Of Costs
TRUE or FALSE: A state may charge any
Case Management and related costs
incurred and reported on their FY‟12 grant
9130 report to their FY‟11 grant if FY‟11
funds are available?
# 10

11. Poll Q: Allocation Of Costs
TRUE or FALSE: A state may charge
Admin costs incurred in FY‟12 to their
FY‟13 grant allocation once those funds
are received.
# 11

12. TAA Current Funding Status
# 12
Allocation FY11 FY12, FY13
Authority TGAAA (‘09) TAAEA (‘11)
Reference TEGL 13-10 TEGL 13-11
Funding
Streams
Separate Grants
1. Program (Training, JS&R)
2. Admin (Admin – CM)
Single Consolidated Grant
Funding
Level
$575 Million
Additional 15% Provided for Admin
and CM + additional $350K for CM.
$575 Million
Restrictions
- Max 2/3 of allocation for Admin
- Min. 1/3 allocation for CM
- max 10% spent for Admin
- min. 5% spent for CM
Expiration 09/30/13 09/30/14…
Active Grant Allocations

13. Benefit to Grant
• Benefit to grant – under the cost
principles (2 CFR 225), a cost must be
allocable to the grant – i.e. the grant
must benefit. So if you are looking at
funding IT infrastructure, you must be
able to clearly document the benefit to
the TAA program
# 13

14. Consistent Treatment
• Consistent treatment – under the cost
principles, a cost must be consistently
treated. This means that if you look at the
One-Stop Resource Sharing agreement
and determine that TAA funds can pay
more (there must be a methodology as to
benefit – see above) – that this must be
consistently applied. You cannot change
how much is contributed each month or
year based on funds availability. Budgets
are not a justification for cost allocation.
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15. Documentation
• Documentation – for all costs, in order to
be found allowable, you must have
policies and procedures to support how
funds are used, as well as supporting
documentation to demonstrate costs are
allowable
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16. Merit Staffing Requirement
• 20 CFR 618.890
– Staff funded under Trade funds must be
state merit staff (except MA, MI & CO)
– Does not apply to non-inherently
governmental functions (OMB Circular A-76)
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17. Case Management & Related Costs
• Page A-50, TEGL 22-08
• “In addition to staff costs for career counselors, the
„employment and case management services‟ funds
may be used for: assessment tests; skills
transferability analysis; peer counselors;
development and provision of labor market
information; maintenance and enhancement of
electronic case management systems to allow for
improved case management services; information
on available training, including provider performance
and cost information; and, any other staff costs
related to case management. This list is not
intended to be all inclusive.”
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18. Trade Funds Can Pay For…
• Operating costs of American Job Centers
• MIS development, appropriate upgrades
and maintenance
• Supplies and equipment
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19. Discussion & Feedback
19#
Questions? Comments?

20. Speaker’s Contact Information
Speaker: Timothy Theberge
Title: Regional Trade Coordinator
Organization: Region 1
Email: theberge.timothy@dol.gov
Telephone: 617-788-0139
Twitter: @timtheberge
Slideshare: www.slideshare.net/ttheberge
20#