DUAL ENROLLMENT NEGs
I. QUALIFYING CRITERIA
One of the first items to be determined when reviewing a NEG application is whether it
meets the eligibility criteria for the type of NEG being requested. If an applicant does not
meet the eligibility criteria, then the NEG application will not be considered. For Dual
Enrollment NEGs, the criteria to be met fall into five major eligibility categories:
applicant, participant, expenditure thresholds, layoff events, and timeliness. An
explanation of each follows:
Applicant Eligibility
According to information on page 23059 of the Workforce Investment Act: National
Emergency Grants-Application Procedures, applicants for a Dual Enrollment NEG are
“limited to states.” Other applicant types are not eligible and the NEG would not be
considered. However, in developing the application, states should consult with the local
area(s) in which the project will operate, as needed.
Participant Eligibility
The application should provide a description of the population to be served. According
to information listed on page 23060 of the Workforce Investment Act: National
Emergency Grants-Application Procedures, individuals from at least one of the included
companies must meet all of the following criteria for a Dual Enrollment NEG to be
appropriate:
covered by a certification or pending a determination under the Trade Adjustment
Assistance (TAA) program
meets the definition of a dislocated worker under the Workforce Investment Act
(WIA)
is co-enrolled/registered in both TAA and WIA
If the application reflects that none of the participants proposed to be served under the
NEG meet these criteria, the application will not be considered. Other non TAA-eligible
individuals can be included in a dual enrollment application consistent with the criteria
described below in the Layoff Event(s) section.
Expenditure Thresholds
According to information on pages 23054 – 23055 of the Workforce Investment Act:
National Emergency Grants-Application Procedures, the main purpose of a Dual
Enrollment NEG is “to provide trade-eligible dislocated workers with “wrap-around”
services that are not available through the Trade program, and state formula Dislocated
Worker [DW] program funds are not sufficient to provide such services…” Although
-2TAA funds may not be used to pay for many wrap-around services, they may be used to
pay for some of these services. Reviewers should determine whether TAA funds are
available by reviewing the ETA 9130 for the TAA program. The ETA 9130 does not
provide specific information about the amount of funding available in specific categories
(such as case management), but will provide the reviewer with an estimate of the total
amount of TAA funding available. If the ETA 9130 shows that a significant portion of
TAA funds is available, then the reviewer should contact the applicant to determine the
reason NEG funding is being requested to pay for TAA-allowable wrap-around services
for the TAA-eligible workers. In addition to TAA funding availability, information
regarding the availability of funds in the DW formula program must also be obtained.
This information must reflect that at least 70% of the previous program year’s DW
formula funds (including any carry-in) have been expended, or drawn down. The source
document that should be used to determine the percentage of funds expended is the DW
formula program ETA 9130 fiscal report. If this report shows that less than 70% of the
funds have been expended, then the reviewer should determine the amount of funds
drawn down to determine if this meets the 70% threshold. Drawdown information can be
obtained from the Payment Management System (PMS). In addition to determining
whether the 70% threshold has been met, the reviewer should also examine the current
year’s expenditure level for the DW formula program to gauge whether a need for the
NEG funds has been sufficiently demonstrated. See the example below:
Example
Applicant X submits a draft application for a Dual Enrollment NEG to its Federal
Project Officer (FPO) for review. The state would like to provide “wrap-around”
(including case management) and training services to all participants, which include
both TAA-eligible and non-TAA eligible participants. The FPO determines that, based
on the information in the most recent ETA 9130, the DW formula program operating in
the applicant’s state expended 80% of its Program Year (PY) 2009 formula funds, which
included carry-in from PY 2008. The FPO also reviews the state’s current year DW
formula expenditure information which shows that it has expended 50% of its DW
formula funds. The FPO is satisfied that the state has met the 70% expenditure threshold
requirement for the DW program and based on the state’s expenditure rate for the
current year, determines that there will not be sufficient DW funds available to serve the
population included in the NEG. However, after reviewing the ETA 9130 for the TAA
program and consulting with colleagues in the Office of Trade Adjustment Assistance
(OTAA), the FPO discovers that the state has expended just 1% of its TAA funds. Based
on this information, the FPO determines that the state may have TAA resources available
for some case management services and requests additional information.
Layoff Event(s)
For an applicant to be eligible to apply for a Dual Enrollment NEG, the layoff event must
meet at least one of the following criteria:
-3Plant Closure and mass layoff affecting 50+ workers at a single site of
employment where the Department of Labor (DOL) has determined that the
workers are TAA-certified or have a TAA petition pending
Layoffs at several companies in a single local community, including layoffs not
meeting the single site criterion that, in total, have significantly increased the total
number of unemployed individuals in the community (criterion applies at the
local level and layoffs must be concentrated within the 6 months preceding the
application) and one of the companies is TAA-eligible/pending a TAA
determination
Layoffs at multiple locations with employers who are in the same industry sector
(of which at least one company must have a layoff of more than 50 workers) and
one of the companies is TAA-eligible/pending a TAA determination
Layoffs at multiple locations (multi-company) that occur within a 4-month period
and in which each layoff impacts 50 or more workers and one or more of the
companies is TAA-eligible/pending a TAA determination
Timeliness of Submission
According to pages 23054 and 23061 of the Workforce Investment Act: National
Emergency Grants-Application Procedures, applications are expected to be submitted no
later than 120 calendar days after the following:
the date the participants to be served under the project became eligible for
assistance; (Note: Workers become eligible for services upon receipt of a layoff
notice or company announcement)
OR
the date of the dislocation event
Applications that are submitted more than 120 days after either of the occurrences above
must provide a reasonable justification for the late submission, along with specific
information that demonstrates the target population’s continued interest in the
reemployment services proposed under the NEG. See the example below:
Example
State X submits a draft application for a Dual Enrollment NEG to its FPO for review on
January 16, 2010. The State is proposing to provide participants with occupational
training and supportive services specified in the application. Upon reviewing the
application, the FPO discovers that the dislocation event, a TAA-certified mass layoff
affecting more than 100 workers from a major employer in the State, occurred in July
2009. However, the State explains the reason for its late submission in its application.
According to the State, it had every intention of submitting the application back in August
2009, but had been significantly impacted by a series of natural disasters including three
floods and two snowstorms since that time. The State relays that responding to these
disasters had consumed much of its time and, as a result, it was unable to submit the
-4application for this NEG in a timely fashion. The State provides great detail about the
time-consuming activities in which it was involved as a result of these disasters and
indicates that the 60 proposed participants are already in TAA-funded training. After
doing some research, the FPO discovers that there were indeed several disasters in the
State during the time period indicated. The FPO believes that this qualifies as a
reasonable justification for the late submission. The State also indicates in the
application that it recently reviewed the participant files and has determined that
transportation assistance is still needed for all 60 of the proposed participants, as the
training providers are 50 and 60 miles away from the affected workers, and 40 of the
proposed participants need help with child care. The FPO contacts his/her Regional
Account Representative in the Office of National Response (ONR) to ensure that this
application will be able to be considered for funding.
II. SF-424
Every Federal agency requires grant applicants to complete a Standard Form (SF) 424
when applying for Federal funding. The NEG electronic application system (eSystem)
will prompt NEG applicants to complete fields on the SF-424. If an applicant fails to
complete the necessary fields, the NEG eSystem will not allow the applicant to submit
the application.
Accuracy and Consistency of Information Provided
Completing the SF-424 is not a perfunctory exercise. It is one of the first items reviewed,
so it is important that applicants complete it correctly. When reviewing an application,
reviewers should verify the information to ensure that it is accurate. For example, an
organization’s Data Universal Numbering System (DUNS) number can be checked by
going to the following website: https://www.bpn.gov/CCRSearch/Search.aspx.
Reviewers should also check to ensure that the Congressional districts listed are accurate,
so that notification of the grant award is provided to the appropriate Members of
Congress. Congressional districts can be checked on the following website:
http://www.nationalatlas.gov/printable/congress.html#list. They should also ensure that
the title of the applicant’s project is descriptive and reflects the NEG type.
In addition to checking for accuracy, reviewers should also ensure that information listed
on the SF-424 is consistent with information listed on other forms in the application
package. For example, the SF-424 requests that applicants list the areas that will be
affected by the project. This information is also requested on the Project Synopsis and
Project Operator Forms and should be consistent with the entries on the SF-424. In
addition, the period of performance listed on the SF-424 should be consistent with the
period of performance shown on the Planning Form. Funding requests should also be
consistent. The amount requested shown on the SF-424 should match the request shown
on the Project Synopsis and the amount shown in the last quarter of the Total
Expenditures: Grantee and Project Operator Level line of the Planning form.
The above items should not be considered an all-inclusive list that reviewers should
check. Reviewers are expected to verify information listed on the form to the extent
-5feasible to ensure the application, once officially submitted, does not contain errors that
would either require that the application be returned for corrections or that a future
modification be submitted to correct the error(s).
III. PROJECT SYNOPSIS
The Project Synopsis form is the “meat” of the application. In addition to identifying key
information regarding the eligible event type, planned number of participants, cost per
participant, Entered Employment Rate (EER) and earnings, this form should provide a
clear description of the reemployment services the project plans to provide, along with a
description of the dislocation event that makes the NEG necessary.
Completion of Applicable Fields/Accuracy and Consistency of Information Provided
Reviewers should ensure that all fields on the Project Synopsis relevant to the applicant
are completed and that the information is both accurate and consistent with other parts of
the application package. For example, the amount of funding listed in the Project
Synopsis should match the funding amount on the SF-424 and the amount shown in the
last quarter of the Total Expenditures: Grantee and Project Operator Level line of the
Planning Form. Examples of other items that should be checked for consistency with
other forms in the package are the project name and the counties included in the project
service area. Reviewers should also ensure that the information provided in the Project
Synopsis is consistent with the information provided in the Narrative Statements and
attachments submitted. This list of items should not be considered all-inclusive.
Reviewers are expected to verify all information listed on the form to the extent feasible,
to ensure the application, once officially submitted, does not contain errors that would
either require that the application be returned for corrections or that a future modification
be submitted to correct the error(s).
Description of Activities to be Undertaken
This section should identify the activities that will be undertaken to address the
participants’ reemployment and training needs. The activities should describe the mix of
services needed to effectively serve participants, such as intensive services, training,
basic skills remediation, and supportive services. Specific information should be
provided around training needs, especially if all of the proposed participants are TAAcertified, or pending a TAA certification. Specific rationale as to why NEG-funded
training and case management services is needed, and how individuals will be
transitioned to TAA-funded training, when available, should be discussed. The narrative
should also discuss how labor market information and participant assessments were used
to inform service strategies, identify skill gaps that need to be addressed, and determine
the types of training needed to move participants into viable and growing occupations.
These target occupations should be specified in the application. Coordination with WIA
and other partners who deliver similar services, should also be addressed.
-6Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a TAA-certified mass layoff. In its Project Synopsis, the applicant indicates
that, based on the participant assessments conducted and national labor market
information about the jobs currently in demand, the participants will be provided with
much needed intensive and training services that will enable them to be placed in jobs
that pay at least $60,000 per year. After reviewing this description, the FPO determines
that the applicant needs to provide additional information including, 1) the specific
intensive and training services that will be provided by the project, and why the training
costs aren’t being covered by the TAA program; 2) the types of occupations in which the
participants would be placed based on local, not national labor market information; and
3) coordination with the WIA programs and other partners.
Description of the Dislocation Event
This section should provide information about the dislocation event that conveys the
impact of the dislocation on the area to be served under the project. Using numerical data
to help convey the extent of the impact may be useful. Information provided in this
section regarding dates of Worker Adjustment and Retraining Notification (WARN) Act
notices, Rapid Response, and layoff dates should match the information provided on the
Employer Data Form(s).
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a mass layoff from a processing plant that is pending a TAA determination.
The applicant indicates that 70% of the participants to be served do not have high school
diplomas and are in need of remediation services in order to be placed in the jobs
specified in the application. The applicant also relays that the unemployment rate in the
local area is 18%, which will make it especially critical to provide this population with
the remediation services so that they can compete for jobs in the area. The FPO
determines that the applicant has sufficiently relayed the impact of the dislocation event
on the area.
Reasonableness of Funding Request
A variety of factors may be used to determine the reasonableness of the funding request.
Key factors, each of which will be discussed in more detail below include:
Scope of the project
Cost per participant
Available funding provided by other programs and projects
Scope of the Project
-7-
In determining whether the applicant’s funding request is reasonable, reviewers should
evaluate whether the number and types of services to be provided, as well as the number
of participants to be served, is commensurate with the amount of funds being requested.
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a TAA-certified mass layoff. The applicant is requesting $5,000,000 to
provide 50 workers with transportation assistance. The FPO determines that the scope
of the project does not justify the amount of funds being requested and relays this to the
applicant.
Cost Per Participant
DW Formula Program
“The planned per participant cost will be expected to be within a reasonable range of the
actual end-of-year average cost per participant for formula-funded dislocated worker
activities in the planned service area during the most recent completed PY, or the state
average if the project is designed to cover multiple local areas. The actual formula
program cost per participant should equal the total expenditures in the DW formula
program for the previous PY divided by the total number of registrants reported for that
PY. This actual cost per participant level must be entered on the Project Synopsis form
in the application” (Workforce Investment Act: National Emergency Grants – Application
Procedures, p. 23062). Applications that do not include the cost per participant
information for the DW program in the previous PY, or the planned cost per participant
under the current NEG, will not be considered until the information is provided.
NOTE: The cost per participant for a Dual Enrollment NEG should be less than the
DW formula program cost because it does not include costs that would be covered
by TAA funds (e.g., training for TAA participants). If the applicant is proposing a
cost per participant that is similar to, or higher than, the previous PY DW formula
cost, the applicant must provide a very strong rationale for this anomaly.
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a mass layoff. The applicant is requesting $500,000 to provide 100 workers
($5,000/participant) with lab technician training. Half of the workers to be served have
been certified as TAA-eligible. Participants will also be provided with “light” intensive
services, specified in the application. The reported cost per participant for the DW
program in the previous PY is $4,000. The FPO determines that, given the fact that half
of the participants are eligible for TAA-funded training, the cost per participant should
be lower, and contacts the applicant for clarification.
-8Other Similar NEGs
In addition to evaluating whether the cost per participant proposed in the NEG under
consideration is similar to the cost per participant for the DW formula program, reviewers
should also evaluate whether the cost per participant is consistent with other similar NEG
projects operating in the area, and if not, determine whether the reason for the
inconsistency is justified. For example, reviewers should assess whether the differences
in the applications, such as the skill level of the population being served, or the services
being provided in the other NEGs are substantial enough to warrant the significant
variance in the cost per participant in the NEG being considered. If the reviewer
determines that the differences in the application do not support the difference in the cost
per participant, then the applicant should be asked to provide an explanation.
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by mass layoffs. Most of the participants to be served under the project have
college degrees and about 60% have been certified as TAA-eligible. The project will
provide participants with supportive and training services. The planned cost per
participant is $7,000. The cost per participant in the DW program for the previous PY
was $7,200. However, the FPO is aware of another Dual Enrollment NEG that has been
awarded in the area over the last year for a worker group with skill levels similar to this
worker group. The cost per participant for that NEG was $3,500. The FPO sees that
there are differences in the number of participants being served and the type of intensive
services and training provided between this NEG and the one currently being considered,
but determines that the differences are slight. As a result of this and the fact that most of
the participants being served are eligible for TAA-funded training, the FPO asks the
applicant to explain the reasons for the significant difference between the cost per
participant for this project and the one currently operating in the area.
Available Funding Provided by Other Programs and Projects
As previously discussed in the Qualifying Criteria section of this Guidebook, reviewers
must determine whether applicants have met the 70% DW formula fund
expenditure/drawdown rate needed to establish eligibility for NEG funds. However,
reviewers may be aware of other funding that has recently been awarded by other
agencies to serve a population similar to the one proposed to be served under the NEG.
For example, the area may have a significant amount of TAA funds available which can
be used to provide training and case management services to TAA-certified participants
in a dual enrollment project. Reviewers may also be aware of funds available through
other programs. If so, reviewers should obtain information from the applicant that
addresses the reason the NEG funds are needed, given the other funds that have been
made available to the area.
Example
-9Applicant X submits a draft application to its FPO to serve workers who have been
affected by a mass layoff. The applicant is requesting $1,000,000 to provide workers
with supportive and training services. The FPO is aware that the project area to be
served recently received $5,000,000 in TAA funding that could be used to provide the
population with training and some case management services. The FPO contacts the
applicant to discuss the need for the amount of funding requested.
Performance Measures
NEG project performance goals must align with the state negotiated Entered Employment
Rate (EER) and the Average Six-Month Earnings goals for the WIA DW program, at a
minimum. Outcomes will be measured according to common performance measures for
employment and training programs. The most recent negotiated goals are available on
the Employment and Training Administration (ETA’s) website at:
http://www.doleta.gov/performance/goals/st_neg_perf_level.cfm. Applicants must
provide projections for a Planned EER and Planned Earnings on the Project Synopsis
Form.
EER and Average Six-Month Earnings Goals
In determining the types of jobs for which participants will be trained and subsequently
placed, NEG applicants, like DW formula fund grantees, are expected to use local labor
market information to determine jobs that are in demand in the local area and the wages
associated with those jobs. Because the DW formula program serves the same population
as NEGs, it is expected that the NEG’s EER and Earnings goals will align with those of
the DW formula program. If the NEG EER and Earnings goals do not align with those in
the DW formula program, the reviewer should request the applicant provide a strong
rationale for the difference.
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a TAA-certified mass layoff. The applicant is proposing an EER of 58%.
The most recent negotiated rate for the DW formula program is 65%. The applicant
explains that the reason for the difference is due to the fact that three major employers in
the area have since gone out of business as a result of the recession, thereby increasing
the pool of available workers and decreasing the pool of available employment
opportunities in the area. As a result, it is no longer possible to obtain an EER of 65%.
The FPO determines that the explanation for the variance in the EER is reasonable and
after determining the entire application meets the requirements, recommends it for
funding.
IV. EMPLOYER DATA FORM
- 10 The Employer Data Form provides employer and dislocation site-specific information
needed to validate eligibility of the dislocation event(s) and the target group of workers.
Reviewers should be cognizant of the following when reviewing Employer Data Forms:
A separate Employer Data Form must be provided for each layoff location,
whether it is a NEG for a single company laying off workers at multiple locations,
or a NEG for multiple companies
All the information in the Employer Data Form (e.g., Location of Facility, Layoff
Dates, TAA Petition, Date Filed, Number of Workers Covered, Planned Number
of Participants, Labor Organization Representation) must be specific to the layoff
location. If the worker group is TAA-certified, the TAA certification must be
uploaded as an attachment to the application in the NEG eSystem.
The address for the company’s headquarters is not acceptable, unless workers at
the headquarters site are being displaced.
All fields must be completed. If the information is not applicable, then N/A
should be entered.
Completion of Applicable Fields/Accuracy and Consistency of Information Provided
Reviewers should ensure that applicants provide an Employer Data Form for each
employer and each location where a layoff occurs(ed). Each Employer Data Form will
need to be reviewed both collectively and as a separate and distinct event for accuracy
and consistency. In instances where multiple Employer Data Forms are submitted, the
reviewer will need to ensure the information on the forms is consistent throughout the
application. For example, the number of locations impacted should coincide with the
number of Employer Data Forms submitted; layoff dates on the Employer Data Forms
should be consistent with the dates the applicant indicates the layoffs occurred in the
Project Synopsis; the Total Number of Planned Participants identified in the application
should be consistent with the totals for all the Employer Data Forms and should be the
same as the number projected to be served with NEG funds throughout the application on
other forms, such as the Project Synopsis and the Planning Forms. For multi-company
industry-wide applications, the North American Industry Classification System (NAICS)
codes on the Employer Data Forms should align with one another. The above items
should not be considered an all-inclusive list that reviewers should check. Reviewers are
expected to verify all information listed on the form to the extent feasible to ensure the
application, once officially submitted, does not contain errors that would either require
that it be returned for correction(s) or that a future modification be submitted to correct
the error(s).
Rapid Response Services
The delivery of a wide range of early intervention services such as those provided
through Rapid Response is vital to an effective reemployment strategy for workers
affected by layoffs. Services provided under Rapid Response are also key in helping
determine the number of participants interested in NEG services and the types of services
needed. This is typically accomplished through the use of field surveys completed by the
- 11 affected workers. Reviewers should ensure that the Employer Data Form(s) include the
number of workers contacted and the number of field surveys completed, and a summary
of the results of the surveys that demonstrate the target population’s interest in the
proposed NEG services is included in the Project Synopsis or elsewhere in the
application.
If no Rapid Response has been conducted, specific information that explains the reason it
was not feasible or appropriate to initiate Rapid Response prior to submitting the
application must be provided. Plausible factors may include resistance by or lack of
cooperation from the employer, large numbers of layoff events statewide in the same time
period, or notification did not provide sufficient lead time prior to the layoff. It is also
critical that the applicant include an explanation of the method used to determine
the number of participants it plans to serve under the proposed NEG and how it
knows that these individuals are in need of, and interested in, services. For Dual
Enrollment NEGs, the number of workers already participating in TAA-funded services
and a discussion of their additional needs could serve as an acceptable justification.
50% or Fewer of the Affected
Historically, not more than 50% of the workers affected by a layoff have been enrolled as
participants and served through NEGs. If the Employer Data Form indicates that more
than 50% of the affected workers will be enrolled in the NEG, the reviewer should ensure
that an appropriate rationale is provided.
Example
Applicant X submits a draft application to its FPO to serve workers who have been
affected by a mass layoff from a large employer in a small rural area that employed many
of the residents. The applicant indicates that no Rapid Response had been provided, as a
large number of layoffs from a variety of companies had taken place statewide around
the same period of time. However, the applicant explained that it had been able to obtain
an estimate of the number of individuals interested in services and the need for services
proposed in the NEG from surveys it had received from a labor/management committee
that the employer and workers had formed. This committee submitted the results of the
surveys to the applicant. The applicant went on to explain that the survey response rate
was 95%, and 80% of the workers expressed an interest in training, as they realize there
are no other companies in the area that employ individuals in the type of manufacturing
occupations from which they are being dislocated. Therefore, the number of participants
to be enrolled in the NEG exceeds 50% of the affected workers. The FPO decides that
the rationale provided is reasonable.
V. PROJECT OPERATOR DATA FORM
- 12 All proposed Project Operators must be identified with an individual Project Operator
Data Form. The Project Operator Data Form should be the result of the applicant’s
receipt of data from each individual local Project Operator and be reflective of true
analysis of need based on the Rapid Response survey data obtained from the target
population. Ideally, the application should reflect that proposed individual operator
staffing, administrative, and participant costs are reasonable and consistent with state or
local policies and that local area(s) available DW formula funds are inadequate to address
the dislocation events referenced in the application.
Completion of Applicable Fields/Accuracy and Consistency of Information Provided
Reviewers should ensure that all fields on the Project Operator Form are completed and
that the information is both accurate and consistent with other parts of the application
package. For example, each county within the designated Project Operator’s area of
service must be listed and be consistent with the counties listed in other parts of the
application package. The sum of all Project Operator funding levels must equal the Total
Expenditures: Project Operator Level captured on the Planning Form. Additionally, the
Funding Level captured on the Project Operator Data Form must be equal to the
subsequently executed subgrantee agreement(s). The Number of Participants listed on
each of the Project Operator Data Forms must add up to the Planned Number of
Participants listed on the Project Synopsis Form and the last quarter of enrollment on the
Planning Form. Start and end dates for each project operator must fall within the
proposed start and end dates identified for the entire project on the SF-424. This list of
items should not be considered all-inclusive. Reviewers are expected to verify all
information included on the form to the extent feasible, to ensure the application, once
officially submitted, does not contain errors that would either require that the application
be returned for corrections or that a future modification be submitted to correct the
error(s).
Structure and Resources of Project Operator
If the project operator does not have a history of operating NEG projects, the application
should provide information which demonstrates that the project operator has the structure
and resources necessary to successfully operate the project and achieve program goals.
For example, to demonstrate its capability of managing the proposed NEG project, the
applicant could provide information about its experience managing other projects in the
past that were similar in size, scope, etc. and the outcomes achieved.
VI. PLANNING FORM
The Planning Form represents the applicant’s participant services and cumulative
quarterly expenditure plan for the use of funds requested during the proposed Grant
Period.
Completion of Applicable Fields/Accuracy and Consistency of Information Provided
- 13 -
Reviewers should ensure that all fields on the Planning Form are completed and that the
information is both accurate and consistent with other parts of the application. For
example, the Total Planned Participants listed in the last quarter of enrollment on the
Planning Form must add up to the Number of Participants listed on each of the Project
Operator Data Forms and must match the Planned Number of Participants listed on the
Project Synopsis Form. The amount of funding shown in the last quarter of the Total
Expenditures: Grantee and Project Operator Level line of the Planning Form must
match the amount of funding listed in the Project Synopsis and the SF-424. This list of
items should not be considered all-inclusive. Reviewers are expected to verify all
information included on the form to the extent feasible, to ensure the application, once
officially submitted, does not contain errors that would either require that the application
be returned for corrections or that a future modification be submitted to correct the
error(s).
Enrollments
Full enrollment of participants must be completed within 180 days of grant award, unless
justified by other circumstances applicable to the layoff event. An example of an
instance where this might not be possible is when an entire plant is being shut down and
layoffs are scheduled to occur over the course of a year. In addition, the enrollments
should coincide with the layoff schedule and local training enrollment cycles. The Exit
figure for the last quarter must equal the Total Planned Participants shown in the last
quarter of enrollment.
Cost Reasonableness
The regulations pertinent to cost analysis in NEGs derive from the Office of Management
and Budget (OMB) Cost Principles which generally require that costs must be
reasonable, necessary and allocable. These principles are codified in the WIA regulations
at 20 CFR 667.200. Historical costs are also often used in analyzing costs by comparing
what the state has done in similar situations with their formula funds. However, since
some costs are being covered by the TAA program, it is not meaningful to compare
overall cost per figures with the WIA formula program. Additionally, local policy plays a
role in what is acceptable in supportive services and NRPs. If NRPs are provided, a copy
of the local NRP policy must be included as a part of the application. The WIA
regulations on supportive services generally require that uniformity be provided for all
dislocated workers in the provision of services in accordance with the local Workforce
Investment Board (WIB) policy.
Here are some items that will help reviewers flag some potential cost issues:
Cost Per Participant
- 14 Overall
What types of participant costs are being covered by other sources? How much?
Taking into consideration allowability, necessity, and the scope and complexity of
the project and the coverage of costs by other sources, is the overall planned cost
per participant reasonable?
Core and Intensive Services
Is the applicant making full use of the TAA program’s coverage of costs for some
of the core and intensive services, or is the applicant charging all these services to
the NEG?
Is this cost within the $2,000-$3,500 norm?
Is the higher cost justified due to mitigating factors in this application, e.g. hardto-serve population?
Support Services
Is this cost within the $2,000-$2,500 norm?
Is the higher cost justified due to mitigating factors in this application, e.g. hardto-serve population?
Does the proposed strategy conform to the local WIB supportive service policy
for all dislocated workers, not just this NEG?
Training Services
For training not covered by other sources (e.g. TAA) is this cost within the
$2,000-$4,000 norm?
For instances where all participants are TAA-certified, are there no NEG-funded
training costs?
Is the higher cost justified due to mitigating factors in this application?
Does the proposed strategy conform to the local WIB training policy for all
dislocated workers, not just this NEG?
Needs-Related Payments (NRPs)
Does the proposed strategy conform to the local WIB NRP policy for all
dislocated workers, not just NEGs?
Does it appear that the local WIB has an understanding of the eligibility
requirements of the regulations as codified by their local policy?
Is this cost justified due to mitigating circumstances?
If NRP processing costs are included, does the cost for this function appear
reasonable given the number of participants receiving NRPs?
Are NRPs limited to only those non Trade Readjustment Allowance (TRA)eligible individuals?
- 15 Administrative Costs
What are the total administrative costs and what percentage of the grant amount
does that represent (exclusive of NRPs)?
If over 10% total, does it appear that they are asking for the 11.5% allowed in the
guidelines, whereby 1.5% is for State administration/oversight and the 10% is for
the Project Operators?
If not and the total administrative cost is over 10%, has justification been
provided in the application to address the fact that they are exceeding the norm?
Indirect Costs
If indirect costs are included in the line item for such, they are to be state level
indirect costs only. For local level indirect costs, it is the responsibility of the
state to administer oversight of such costs and indirect cost approvals. When
local level indirect is included it should be listed in the “Other” line item or in the
Project Operator administrative or program line items.
If indirect costs are included, is there a copy of the current Federal cognizant
agency’s approval document for the rate or cost allocation plan uploaded as an
attachment to the application? Applicants should not upload a copy of the
indirect cost plan document; only the approval for that document is needed.
If the indirect costs are higher than $10,000, the reviewer should ask that the
calculation used to arrive at the line item cost figure be included in the Narrative
Statements section of the application if it wasn’t provided.
“Other” Costs
These costs must be accompanied by an appropriate listing and description of the
component costs for these line item figures (2 each at the Grantee and Project Operator
levels). The narrative must be included in the Narrative Statements portion of the
application.
VII. NARRATIVE STATEMENTS
This section of the application should provide many of the explanations/justifications
needed for entries in the previously mentioned application forms. According to
information listed on page 23063 of the Workforce Investment Act: National Emergency
Grants-Application Procedures; narrative explanations are required in the following
instances:
A notification was made by the employer but no Rapid Response activities
have been initiated.
Some of the affected layoffs have occurred more than four months prior to the
date of submission of the application, and additional information is required to
- 16 document that workers are in need of and available for employment–related
assistance.
The application is being submitted to address ‘‘community impact layoffs.’’
The narrative must provide specific information in relation to the requirements
for meeting this criterion.
The number of affected workers that will be enrolled as participants is a
higher percentage than has been historically served through NEGs (e.g., >50
percent).
The planned average cost per participant on the project is outside a reasonable
range of the actual average cost per participant for formula funded dislocated
worker activities, as appropriate, for the most recent completed PY.
There are participants planned to receive NRPs, which requires explaining
how the planned number of recipients and the NRP cost per participant were
determined.
Indirect costs are included in the application, which requires identifying the
following: cognizant approval agency, approved cost rate and base, and date
of approval.
Administrative costs related to NRPs are included in the budget, which
requires explaining how the administrative cost estimate was derived (e.g.,
based on number of check payments and check processing costs).
Administrative and/or other costs are included, which requires a delineation of
the components (e.g., staffing, travel, facilities) and amounts of such costs.
The applicant is free to include narrative explanations of other special factors, but the
narrative should be concise and informative in relation to the application evaluation
criteria.
Accuracy, Consistency, and Legibility of Information Provided
Where the applicant has provided additional details or uploaded documents, those details
or documents should support or align with the information included in other parts of the
application. All uploaded documents must be accessible and legible.
Note: Uploaded documents are limited to PDF files, Microsoft Word documents and
Microsoft Excel spreadsheets.
Delineation of Cost Components and Reasonableness of Costs
This section should be used to delineate administrative costs at the Grantee and Project
Operator level, as well as “Other” costs listed. In reviewing the cost for each component,
reviewers should consider the reasonableness of the costs when compared to factors such
as project scope and complexity. A brief explanation of the types of the expenditures that
should be included follows:
Grantee Costs/Administration
- 17 Includes expenditures that will be incurred by the Grantee entity directly; e.g. Program
Management and Oversight activities, and should not include any expenditure(s) that will
be incurred by the Project Operator(s) through subgrant agreements.
Project Operator Costs/Administration
Includes planned expenditures that will be incurred by Project Operator(s) and their
service providers.
Note: If the Grantee is also the Project Operator, this will include the planned
expenditures for direct participant services incurred by the Grantee as the Project
Operator, not included in the Grantee-Level Expenditures.
Other Costs
Any entry other than “0” for this item will require a narrative statement identifying the
specific activities and the estimated cost of each item. For example, a statement such as
the following would provide a good sense of the items that comprise Other costs:
Program management and oversight of $5,652 will be used for expenses including: staff
travel ($229); facilities and communications ($1,319); supplies ($902) and administrative
system improvements, audit services, liability insurance, network maintenance and
dues/subscriptions ($3,202).
Equipment Purchases/Leases
As a condition of the grant, the applicant must provide adequate justification for
equipment purchases and leases.
Note: Equipment is defined at both 29 CFR 97.3 and 95.2 as tangible property having a
useful life of more than one year and per unit cost of $5,000 or more, and must have prior
approval from the Grant Officer.
VIII. POLICY ISSUES
Sometimes NEG applications raise policy issues in the form of questions or concerns;
typically relating to the allowability of proposed activities according to established law,
regulations, or policy. While answers to some policy issues are clearly provided in the
law, regulations, or ETA guidance and can be quickly addressed by Regional Offices,
others may require further research, consultation, interpretation and resolution by
program/legal specialists in the National Office. It is the role of ONR to clarify vague or
ambiguous policies in existing guidance, develop new proposals or policies, and facilitate
resolution of issues.
Example
- 18 A FPO received an application for a dual enrollment NEG. As part of its submission, the
state requested intensive services, including resources for case management. However,
the FPO knows that the Trade and Globalization Adjustment Assistance Act of 2009 went
into effect May 18, 2009 and authorizes career counseling and case management. The
FPO decides to consult with the National Office on the allowability of requesting
resources for case management under this application.
