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Employment and Training Administration Advisory System U.S. Department of Labor
Washington, D.C. 20210 |
CLASSIFICATION
Financial Reporting/CFDA Nos. CORRESPONDENCE SYMBOL OFAM DATE June 11, 2002 |
TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 29-01
| TO: |
ALL STATE WORKFORCE LIAISONS ALL STATE WORKFORCE AGENCIES ALL STATE WORKER ADJUSTMENT LIAISONS ALL ONE-STOP CENTER SYSTEM LEADS |
| FROM: | EMILY STOVER DeROCCO Assistant Secretary | |
| SUBJECT: | Appropriate Catalog of Federal Domestic Assistance Identification of WIA Awards and Subawards; Financial Reporting of WIA Cluster Funds |
| EXPIRATION DATE | RESCISSIONS |
| Continuing |
The Compliance Supplement is a compilation of federal program requirements developed to assist auditors in performing audits of entities covered by the Single Audit Act and OMB Circular A-133. Circular A-133 is a common rule adopted by all federal grant-making agencies; the DOL regulation at 29 CFR Part 99 is the DOL version of this common rule. Part 99 is available at the National Archives Access Internet website at http://www.access.gpo.gov/nara/cfr/index.html. Both Circular A-133 and the most recent Compliance Supplement are available at OMB's Internet website at http://www.whitehouse.gov/omb/grants/index.html.
Coverage of WIA in the CFDA and the Compliance Supplement. After WIA's enactment, the Employment and Training Administration developed a single CFDA description, CFDA No. 17.255, for all activities authorized under Title I of WIA. This program description included all formula grant activities under Subtitle IB funded with Adult, Youth, and Dislocated Worker (DLW) funds, Job Corps grants and contracts under Subtitle IC, and the various programs and activities under Subtitle ID, including Indian and Native American (INA) Programs, National Farmworker Jobs Programs (NFJP), Youth Opportunity Grants (YOG), Veterans' workforce investment programs (administered by the Veterans' Employment and Training Service), Demonstration, Pilot, and Research activities, Evaluations, and National Emergency Grants (NEG). Use of a single program description was a departure from past practice in which each of the major funding streams under the Job Training Partnership Act (JTPA) and earlier employment and training legislation were separately described in the CFDA. The rationale for having a single program description was to reflect the Act's objective of bringing the various federal workforce programs together into a single delivery system. Thus, each component of the system was treated as a part of a single whole.
The WIA program first appeared in the OMB Circular A-133 Compliance Supplement in April 2001. The WIA program description in the 2001 Compliance Supplement, which was titled "CFDA 17.255 WORKFORCE INVESTMENT ACT (WIA Title I)," covered the six largest WIA Title I grant program components described in the CFDA's WIA program description. They were the three Subtitle IB funding streams - Adults, Dislocated Workers, and Youth, and the Indian and Native American Programs, National Farmworker Jobs Programs, and Youth Opportunity Grants components from WIA Subtitle ID. Later in 2001, ETA replaced the single WIA program description in the CFDA with six new program descriptions: 17.258 - WIA Adult Program; 17.259 - WIA Youth Activities; 17.260 - WIA Dislocated Workers; 17.261 - ETA Pilots, Demonstrations, and Research Projects; 17.262 - ETA Evaluations; and 17.263 - Youth Opportunity Grants. In addition, the CFDA descriptions of the JTPA Indian and Native American Program (17.251) and Migrant and Seasonal Farmworkers (17.247) were retained in the Catalog as WIA categories, and the single WIA program description was removed. This created an inconsistency between the CFDA and the Compliance Supplement, which is the source of many questions from grantees and auditors.
Since the Compliance Supplement is based on the CFDA structure, the 2002 Compliance Supplement contains the following WIA Title I program descriptions: Workforce Investment Act State and Local Government Programs Cluster, containing WIA Adult Program (CFDA 17.258), WIA Youth Activities (CFDA 17.259), and WIA Dislocated Workers (CFDA 17.260); Youth Opportunity Grants (CFDA 17.263); Indian and Native American Employment and Training Programs (CFDA 17.251); and the National Farmworker Jobs Program (CFDA 17.247). However, the same mismatch between the CFDA and the Compliance Supplement will return for the WIA Indian and Native American Employment and Training Programs and the
National Farmworker Jobs Program, which are in the process of getting new CFDA numbers (17.265 for INA and 17.264 for NFJP).
Preparation of financial statements & cash drawdown requests involving the WIA Cluster. The structure of ETA financial reports for the WIA Cluster - Adults, Dislocated Workers, and Youth activities - presents a special problem of how to prepare financial statements that reflect financial activity involving funds that have been pooled in the Statewide Reserve, or funds that have been merged by local areas for administrative expenditures. These funds may be merged and expended without regard to whether the amount expended from each source is proportionate to the benefit received by that source.
In PY 2000, all WIA Title I financial transactions were considered to involve only a single fund source. Consequently, pooling of WIA Cluster funds by states or local areas was not an issue. Similarly, there was no need to allocate program income or disbursements among the three WIA Cluster funding streams. That all changed in PY 2001, due to a change in the treatment of what were previously considered funding streams or components of a single WIA Title I program to programs in their own right. As a result, certain financial operations, such as preparing financial statements or cash drawdown requests, must now be performed by disaggregating expenditures or estimated cash disbursements of pooled funds and assigning them to the three contributing fund sources. Paragraph 6. below provides guidance on how this may be done.
4. Policy. ETA award documents have not always used correct CFDA identifiers or have not used any CFDA identifier. Effective immediately, all new ETA award documents, including plan approvals, new awards, modifications to existing awards, and notices of obligation will use appropriate CFDA numbers.
5. Identification of ETA Awards by CFDA Number. The following CFDA numbers apply to ETA awards of WIA Title I funds for the periods indicated and should be used for all purposes where the use of a CFDA number is required. No CFDA number has been assigned to WIA performance incentive grants as of this date.
| Program | CFDA Number | Award Period Covered |
| WIA formula funds - Adults | 17.258 | 7/1/01 onward* |
| WIA formula funds - Adults | 17.255 | 7/1/00 - 6/30/01* |
| WIA formula funds - Youth | 17.259 | 4/1/01 onward* |
| WIA formula funds - Youth | 17.255 | 4/1/00 - 3/31/01* |
| WIA formula funds - Dislocated Workers (DLW) | 17.260 | 7/1/01 onward* |
| WIA formula funds - DLW | 17.255 | 7/1/00 - 6/30/01* |
| WIA Youth Opportunity (YOG) | 17.263 | 7/1/01 onward |
| WIA Youth Opportunity (YOG) | 17.255 | 7/1/00 - 6/30/01 |
| WIA Youth Opportunity (YOG) | 17.249 | 7/1/99 - 6/30/00 |
| Program | CFDA Number | Award Period Covered |
| WIA Indian & Native American (INA) | 17.265 | 7/1/02 onward |
| WIA INA | 17.251 | 7/1/01 - 6/30/02 |
| WIA INA | 17.255 | 7/1/00 - 6/30/01 |
| WIA Migrant & Seasonal Farmworkers(MSFW) | 17.264 | 7/1/02 onward |
| WIA Nat'l Farmworker Jobs Program (NFJP) | 17.247 | 7/1/01 - 6/30/02 |
| WIA NFJP | 17.255 | 7/1/00 - 6/30/01 |
| WIA Nat'l Emergency Grants (NEG) | 17.260 | 7/1/01 onward* |
| WIA Nat'l Emergency Grants (NEG) | 17.255 | 7/1/00 - 6/30/01* |
| DLW-Tech Asst & Tng | 17.260 | 7/1/01 onward |
| DLW-Tech Asst & Tng, | 17.246 | 7/1/00 - 6/30/01 |
| DLW-Demonstration grants | 17.260 | 7/1/01 onward |
| DLW-Demonstration grants | 17.246 | 7/1/00 - 6/30/01 |
| WIA Pilots, Demos, & Research | 17.261 | 7/1/01 onward ** | WIA Evaluations | 17.262 | 7/1/00 onward |
* CFDA numbers do not appear on the grant documents for the indicated funding streams.
** Does not include pilots, demos, & research projects funded with DLW funds under 17.255 or 17.260, as applicable.
6. Financial Reporting Issues Resulting From The New Program Structure
WIA Cluster funds (Adults, Dislocated Workers, and Youth activities funds) may be merged, expended up to the statutory limits for Statewide Activities or for local administrative expenditures, and reported to ETA without regard to the relative benefits received by the contributing fund sources. However, in order to perform certain financial operations, such as preparing recipients' and subrecipients' year-end financial statements required under Circular A-133, it is necessary to first disaggregate merged amounts and combine them with other funds from the original three fund sources. We suggest that this be done using the same methodology DOL uses to calculate obligations and expenditures by fund source.
DOL determines each fund source's proportion of the total amount of WIA Subtitle IB funds allotted to a state for a given program year. It then applies these percentages to that year's merged funds to determine the total expenditures or obligations for each fund source. For example, in a state that received $3,000,000 total Subtitle IB funding, consisting of: $1,200,000 (40%) Adult funds, $1,050,000 (35%) Youth funds, and $750,000 (25%) Dislocated Worker funds, if the state took the maximum 15% from each fund source for the State Reserve, the State Reserve would then total $450,000. If State Reserve expenditures in a given period were $100,000, then $40,000 (40%) could be applied against Adult funds (CFDA 17.258) on the schedule of expenditures, $35,000 (35%) against Youth funds (CFDA 17.259), and $25,000 (25%) against Dislocated Worker funds (CFDA 17.260). We believe many recipients are already using this methodology for determining what fund source to charge for cash drawdowns obtained through the Payment Management System (PMS), since the PMS coding structure for WIA funds is also based on the three Subtitle IB funding streams.
Recipients are required to report program income earned and used to ETA. Since all financial reporting to ETA is based on fund source, i.e., WIA Subtitle IB funding stream and fiscal/program year of federal funds, recipients must assign program income earned and used to the WIA fund source(s) to which it is related for financial reporting purposes. Thus, if in the example in Paragraph 6.a. above, $6,000 of program income was earned on Statewide Reserve funds, $ 2,400 (40%) would be allocated to Adult funds, $ 2,100 (35%) would be allocated to Youth funds, and $1,500 (25%) would be allocated to Dislocated Worker funds.
Special attention should be given to interest earned on advances of grant funds. Interest earned on WIA cash drawdowns by states through the PMS is subject to both CMIA requirements and WIA provisions requiring it to be treated as program income (WIA Sec. 195(7)(B)(iii)). The CMIA and its implementing regulations at 31 CFR Part 205 establish procedures governing federal cash advances to states for administering federal financial assistance programs, including the establishment and liquidation of reciprocal interest liabilities between the federal government and the states.
During PY 2000, all WIA Subtitle IB activities covered under CMIA reciprocal interest agreements with the U.S. Treasury (CMIA agreements) used CFDA No. 17.255. This year, and for as long as WIA Subtitle IB funds are separately awarded under the three CFDA numbers, one or more of the three funding streams may not exceed the threshold established for inclusion in a state's CMIA agreement. A state must treat any interest earned on advances of WIA funds that is not used to liquidate the state's CMIA liabilities as program income, regardless of whether all three WIA Cluster programs are covered by the state's CMIA agreement or not.
In the example above, if all of the $6,000 of program income was interest on advances and the state's CMIA threshold was $2,000, the $1,500 of interest income allocable to Dislocated Worker funds would not be subject to the CMIA process and would be reportable program income. The interest income allocable to Adult and Youth funds would be subject to the CMIA process. If the interest income was paid to Treasury, it would not be reportable program income. However, if the interest income was not paid to Treasury for any reason, it would be reportable program income. The grantee is responsible for determining whether any interest income subject to the CMIA process was not paid to Treasury and was therefore reportable program income.
7. Action Required. State agencies should review their policies, procedures, and financial records to determine that WIA funds are properly identified by CFDA number and that, where necessary, acceptable procedures are being used to allocate reported financial results to the affected sources of funds.
8. Inquiries. Please refer any questions to Dan Burkitt on 202-693-3024 or Ed Donahue on 202-693-3157.