TEGL_2-16_acc.pdf

ETA Advisory File
TEGL_2-16_acc.pdf (489.75 KB)
ETA Advisory File Text
EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION Financial Reporting CORRESPONDENCE SYMBOL OMAS OGM DATE July 14 2016 RESCISSIONS EXPIRATION DATE TEGL No. 13 -12 Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 2-16 TO STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS ALL DIRECT ETA GRANT RECIPIENTS F ROM PORTIA WU s Assistant Secretary S UBJECT Revised ETA-9130 Financial Report Instructions and Additional Guidance 1. P urpose. To inform the workforce system of updates to the Employment and Training Administration s ETA s 9130 Financial Report and Instructions hereafter referred to as ETA-9130 or 9130 and to provide information and additional guidance regarding new and revised reporting requirements. The 9130 reporting instructions are the primary sources for detailed instructions to complete and submit financial reports and this Training and Employment Guidance Letter TEGL should be used as a supplemental resource. The appropriate program rules regulations and terms and conditions of the grant award may also contain specific reporting guidelines. Therefore this TEGL does not contain information about all sections or line items on the 9130 rather it only covers areas where additional clarification or guidance will help ensure consistent and accurate financial reporting.2. Re ferences. W orkforce Innovation and Opportunity Act WIOA Pub. L. 113-128 Titles I III and V as amended 2 CF R Part 200 Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal Awards Final Rule 2 CF R Part 2900 Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal Awards Final Rule One -Stop Comprehensive Financial Management Technical Assistance Guide TAG Part II Tr aining and Employment Guidance Letter TEGL No. 8-15 Second Title I WIOA Youth Program Transition Guidance TEG L 23-14 Workforce Innovation and Opportunity Act WIOA Youth Program Transition 2 TEGL 26-14 Workforce Innovation and Opportunity Act Transition Authority for Flexible Use of State Rapid Response Funds TEGL 15-14 Implementation of New Uniform Guidance Regulations TEGL 12-14 Allowable Uses and Funding Limits of Workforce Investment Act WIA Program Year PY 2014 funds for Workforce Innovation and Opportunity Act WIOA Transitional Activities 3. Background. ETA awards approximately 8 billion in formula and discretionary awards each year to an average of 1 000 recipients. Financial reports for each of these awards must be submitted quarterly on the ETA-9130 Financial Report. ETA awards include but are not limited to 1 State Employment Security Agencies which are comprised of three components Wagner-Peyser Employment Service Unemployment Insurance program and Trade Adjustment Assistance TAA program grants 2 Workforce Innovation and Opportunity Act WIOA Youth Adult and Dislocated Worker DW programs 3 National Farmworker Jobs Program NFJP 4 Indian and Native American programs 5 the Senior Community Service Employment Program 6 awards authorized under section 169 of WIOA and 7 H-1B Job Training awards. Financial reporting requirements for Federal grants prescribed by the Office of Management and Budget OMB have changed with the implementation of the Uniform Guidance at 2 CFR Part 200 including the Department of Labor s DOL s approved exceptions at 2 CFR Part 2900 . ETA requires that recipients of Federal awards report on an accrual basis. These changes affect both the ETA-9130 reporting form and its instructions. However the changes brought about by the Uniform Guidance do not affect the collection burden on recipients but rather only update certain key terms and definitions. Additionally with the passage of WIOA there are numerous new statutory requirements that impact financial reporting including but not limited to new and or revised limitations and baselines that require the addition of new reporting line items and modification of existing reporting line items on ETA-9130 Financial Reports. Other reporting line items have been added and or removed in an effort to streamline Federal financial reporting and make the 9130 more closely resemble the SF-425 OMB 0348-0061 which is the standard financial reporting form for Federal grant recipients. 4. Financial Reporting Process. The process to certify and submit the financial reports remain mostly unchanged. ETA requires all grant recipients to submit ETA-9130 Financial Reports electronically through an on-line reporting system at www.etareports.doleta.gov. A. Password and PIN Assignments The filing of the ETA-9130 forms requires recipients to certify and submit the reports. A recipient obtains access to the online financial reporting system through the use of a password and PIN. Passwords and PINs should be obtained immediately upon receipt of the grant award. A request for a password and PIN must be submitted via e-mail to ETApassword.pin dol.gov. Passwords and PINs are sent to the primary contact person 3 via e-mail. The Financial Reporting Access Request Document is available on ETA s official Website at http www.doleta.gov grants financial reporting.cfm. Recipients must ensure that the certifying official s information remains current and correct. To request changes to the certifying official you must send an e-mail to ETApassword.pin dol.gov with the grant agreement numbers affected by the change grant recipient name primary contact name contact phone number and contact e-mail address. Please indicate in the change request if the request is a name change only or a new password and PIN is also needed. B. Report Submission Report submission is a three step process 1. Data Entry The secondary contact person designated by the recipient organization is responsible for entering the required data on the ETA-9130 using the password. Most often the secondary contact person is a designated finance reporting person with a limited role in program grant implementation. In these instances it may be necessary for the secondary contact person to collaborate with applicable staff responsible for program grant implementation and or reporting to facilitate complete and accurate financial reporting. This applies particularly when recipients utilize separate systems for financial and grant activity tracking or when recipients accounting systems are on a cash basis as described in the Reporting Requirements section of this TEGL. 2. Data Certification The primary contact person the designated authorized official in the recipient organization is responsible for certifying the accuracy of the data by entering the PIN. The grant recipient is responsible for ensuring that the designated authorized official is a current employee. The PIN takes the place of a signature to certify the data and submission date. 3. Data Acceptance ETA staff is responsible for reviewing the certified ETA-9130 communicating with recipients as necessary and accepting the report within 10 business days after report certification. If a modification is required the certification and acceptance processes must be repeated. If there is a rejection of a report a reason for the rejection must be entered in section 12 Remarks by the ETA reviewer. The reviewer must notify the recipient regarding the 9130 rejection. The recipient revises the 9130 based on the information provided by the reviewer in the Remarks section. The recipient re-certifies and re-submits the 9130 for acceptance. The recipient must inform the Regional Office or Federal Project Officer FPO after any re -certification and re-submission of a 9130. C. Reporting Requirements Financial reports are due no later than 45 calendar days after the end of each quarter unless otherwise specified in reporting instructions. A report must be submitted for each 4 subaccount listed in the Notice of Award NOA document . All financial data must be reported based on the accrual basis of accounting and be cumulative by fiscal year of appropriation through the entire period of performance POP . Recipients are not required to convert their accounting system if it is not on an accrual basis. Instead reports and accrual information must be developed through best estimates based on an analysis of the documentation on hand. For Quarters Ending Financial Reports Due Dates March 31 May 15 June 30 August 14 September 30 November 14 December 31 February 14 The deadlines for ETA-9130 submissions do not change even in instances when the reporting due date falls on a weekend or holiday. The on -line reporting system is available 24 hours a day 7 days a week and reports can be submitted in advance of the due date. However technical support is only available Monday through Friday. The qu arter in which financial reporting begins is based on the effective date listed on the NOA and is independent of the date on which the NOA is signed by the Grant Officer. Examples of due dates for initial 9130 reports are NOA Effective Date NOA Date Signed Initial Reporting Quarter End Date Initial Report Due Date 7 1 15 7 1 15 9 30 15 11 14 15 10 1 15 12 28 15 12 31 15 2 14 16 8 1 16 9 28 16 9 30 16 11 14 16 Quarterly financial reports are locked once ETA has accepted reports for two successive qu arters. Once reports are locked additional adjustments may be made only in limited circumstances and with approval from ETA. The reports are cumulative so any minor adjustments should be made to the next submitted report with an explanation of the change in the Remarks section. At the end of a grant two reports must be submitted 1. The Final 9130 report must be submitted no later than 45 calendar days after the reporting period in which the grant period of performance expires or all funds are expended whichever comes first. The Final 9130 report must be indicated by selecting Yes in the reporting line item 6 Final Report. 2. The Closeout 9130 report must be submitted no later than 90 calendar days after the expiration of the grant period of performance. The Closeout 9130 Report must be completed in addition to the Final 9130 report. It becomes accessible online after submission of the Final 9130 report at which time a link to the closeout system will 5 also appear. The closeout package can be accessed via the following URL https www.etareports.doleta.gov CFDOCS grantee prod reporting index.cfm. Example of due dates for Final and Closeout 9130 reports are liste d below Grant POP All Funds Expended or POP Expired Final Reporting Quarter End Date Final Report Due Date Closeout Report Due Date 7 1 15 6 30 18 6 30 18 6 30 18 8 14 18 9 28 18 10 1 15 9 30 18 9 30 18 9 30 18 11 14 18 12 29 18 8 1 16 7 31 17 1 6 17 3 31 17 5 15 17 10 29 17 Closeout 9130 reports are due 90 calendar days after the expiration of the POP regardless of whethe r funds are expended prior to that date. Please contact your FPO for assistance with completing the 9130 reports including the Final 9130 report . For questions regarding the Closeout 9130 report please consult the Closeout Specialist assigned to the award. Technical assistance with the on-line reporting system should be directed to the Grantee Reporting System helpdesk at appsupport.egrants dol.gov. For more information regarding grant closeout please visit http www.doleta.gov grants grant closeout.cfm. 5. Overall Changes. The list below provides a summary of the overall significant ETA-9130 report changes. For a comprehensive account of all changes please refer to the ETA -9130 form and its instructions which are available at http www.doleta.gov grants financial reporting.cfm. Changes to program specific 9130 reports are outlined in item 6 below. A. Report Names An alphanumerical character has been assigned to the individual programs ETA-9130 Report s for clarity and better distinction. Basic ETA-9130 Statewide Youth ETA-9130 A Local Youth ETA-9130 B Statewide Adult ETA-9130 C Local Adult ETA-9130 D Statewide Dislocated Workers ETA-9130 E Local Dislocated Workers ETA-9130 F National Dislocated Worker Grants ETA-9130 G NEW Statewide Rapid Response ETA-9130 H Employment Services and Unemployment Insurance ETA-9130 I National Farmworker Jobs Program ETA-9130 J Senior Community Service Employment Program ETA-9130 K 6 Indian and Native American Program ETA-9130 L Trade Adjustment Assistance Program ETA-9130 M B. Conformance to Federal Financial Report SF-425 WIOA promotes accountability and transparency. To assist in this effort ETA attempted to streamline Federal financial reporting by bringing 9130 requirements as close as possible to the already existing SF-425 report. In an effort to alleviate reporting burden Recipient Share of Unliquidated Obligations and Recipient Share of Obligations have been removed and are no longer reporting requirements on the 9130. New lines for Indirect Expenditures reporting have been added to all 9130s with the exception of the Local Youth B Local Adult D and Local Dislocated Workers F rep orts. Additional information on the tracking and reporting of indirect expenditures can be found in the Uniform Guidance at 2 CFR Part 200. The following should be considered for these reporting line items Per 2 CFR 200.56 Indirect F A costs means those costs incurred for a common or joint purpose benefitting more than one cost objective and not readily assignable to the cost objectives specifically benefitted without effort disproportionate to the results achieved. While some administrative costs may be indirect costs the two must not be generally equated. Indirect Expenditures reported on lines 13a 13h are a portion of the Total Administrative Expenditures reported on line 10f. For more information regarding the Total Administrative Expenditures reporting line item please refer to item 7. A. below. Recipients only need to fill out the new Indirect Expenditure lines at 13a h in their submission of the Final 9130 report. Direct grant recipients that have approved negotiated indirect cost rates must complete this section and itemize the rates and costs charged to the grant for the entire period of performance on the Final 9130 report. Recipients that are subject to a statewide cost allocation plan SWCAP do not have to complete this section. Only indirect expenses incurred by the recipient receiving direct awards from ETA must be reported indirect costs incurred by subrecipients are not included on line item 13a-h . Multiple values may be entered in each Indirect Expenditure reporting line item 13a-h for instances in which more than one rate applies to the applicable grant period of performance. 7 6. Changes to Individual ETA-9130 Financial Reports. A. WIOA Program New National Dislocated Worker Grants Report ETA-9130 G Due to the programmatic requirements in WIOA a new report has been created for National Dislocated Worker Grants. Effective with the quarter ending on September 30 2016 all National Dislocated Worker Grant funds including those awarded under the Workforce Investment Act National Emergency Grants must be reported in this new form in compliance with applicable program rules regulations and or grant award terms and conditions. The National Dislocated Worker Grants 9130 G varies from the Basic 9130 in that it contains the following two additional reporting line items in section 11 Additional Data Required Transitional Jobs Expenditures WIOA sec. 134 d 5 sets an expenditure cap of ten percent of the amount of Federal funds allocated to a local area to carry out the Adult and DW programs for a program year or grant period on Transitional Job s Expenditures. Because the National Dislocated Worker Grants program is so closely related to the Adult and DW programs ETA has chosen to also apply this requirement to expenditures for transitional jobs under National Dislocated Worker Grants. Transitional Jobs subject to this cap are 1 time-limited work experiences that are subsidized and are in the public private or nonprofit sectors for individuals with barriers to employment who are chronically unemployed or have an inconsistent work history 2 combined with comprehensive employment and supportive services and 3 designed to assist eligible participants to establish a work history demonstrate success in the workplace and develop the skills that lead to entry into and retention of unsubsidized employment. Training Expenditures This line item should consider all costs for training including but not limited to tuition books tools etc. as applicable. All forms of training must be accounted for including but not limited to occupational skills training high school equivalency GED HiSET TASC training and on-the-job training OJT . New WIOA Statewide and Local ETA-9130 Forms ETA-9130 A B C D E F and H It is important to note that for reporting under WIOA Title I formula grants the level of the report that is statewide versus local determines what data should be reported. With 8 the exception of reporting line item 10a . Cas h Receipts local reports are the aggregate of data collected by the State and reported by local area s in their official accounting records. WIOA Statewide Reports ETA -9130 A C E and H Out -of-School Youth Funds Expended on Direct Services A new reporting line item for Out -of-School Youth Funds Expended on Direct Services was added to the Statewide Youth ETA -9130 A in accord ance with WIOA sec. 129 a 4 A which requires that a minimum of seventy -five percent of statewide and local youth funds respectively must be expended to provide youth workforce investment activities for out -of -school youth. Local out -of- school youth funds are reported separately on the Local Youth ETA -9130 B . For more information regarding Title I youth formula funds the activities associated with the implementation of WIOA and expenditure rate requirements and calculations please refer to TEGL 23 -14 Workforce Innovation and Opportunity Act WIOA Youth Program Transition and TEGL 8 -15 Second Title I WIOA Y outh Program Transition Guidance . In -School Youth Funds Expended on Direct Services Since WIOA sec. 129 a 4 A requires that a minimum of seventy -five percent of statewide and local youth funds respectively must be expended to provide youth workforce i nvestment activities for out -of -school youth in-school youth expenditures must be collected in order to determine the total percentage of out - of-school youth funds expended. Local in -school youth funds are reported separately on the Local Youth ETA -9130 B . The calculation to determine out - of-school youth expenditures is out -of-school youth expenditures divided by in - school plus out -of-school youth expenditures OSY ISY OSY . A new In- School Youth Funds Expended on Direct Services reporting line item was added to the Statewide Youth ETA -9130 A accordingly. Rapid Response Funds Expended on Other Statewide Programs A new Rapid Response Funds Expended on Other Statewide Programs reporting line item was added to the Statewide Rapid Response ETA -91 30 H report in accord ance with WIOA sec. 134 a 2 A ii which stipulates that Rapid Response funds that remain unobligated after the first program year for which such funds were allotted may be used by the Governor to carry out statewide activities authorized under WIOA sec. 134 a 2 B or WIOA sec. 134 a 3 A . WIOA Local Report s ETA -9130 B D and F Work Experience Expenditures A new reporting line item for Work Experience Expenditures was added to the Local Youth ETA -9130 B in acc ord with WIOA sec. 129 c 4 which requires that a minimum of twenty percent of Federal funds allocated to a local area to carry out the local youth program for a program year must be expended on work 9 experience activities. Activities to be considered in this reporting line item are paid and unpaid work experiences for both in-school and out-of-school youth that have as a component academic and occupational education. This may include summer employment opportunities and other employment opportunities available throughout the school year pre-apprenticeship programs internships and job shadowing and OJT opportunities WIOA sec. 129 c 2 C . See TEGL 8-15 Second Title I WIOA Youth Program Transition Guidance for additional information. Pay-for-Performance Contract Expenditures A new Pay-for-Performance Contract Expenditures reporting line item was added to the Local Youth B Local Adult D and Local Dislocated Workers F 9130 reports in accord with WIOA sec. 129 c 1 D and WIOA sec. 134 d 1 A iii . Not more than ten percent of the amount of Federal funds allocated to a local area may be reserved and used for pay-for-performance contract strategies. Additional guidance and technical assistance on the topic of pay-for- performance contract strategies is forthcoming. Federal Share of Unliquidated Obligations for Pay-for-Performance Contracts It is necessary to identify the unliquidated obligations because WIOA sec. 189 g 2 D stipulates that funds for pay-for-performance contracts remain available until expended. Consequently this new reporting line item was added to the Local Youth B Local Adult D and Local Dislocated Workers F 9130 reports . The funds reported in this line item are a portion of the funds reported in the pre-existing reporting line item 10g Federal Share of Unliquidated Obligations. Additional guidance and technical assistance on the topic of pay-for- performance contract strategies is forthcoming. Transitional Jobs Expenditures A new Transitional Jobs Expenditures reporting line item was added to the Local Adult D and Local Dislocated Workers F 9130 reports in accord with WIOA sec. 134 d 5 which sets an expenditure cap for this service strategy of ten percent of the amount of Federal funds allocated to a local area to carry out the Adult and DW programs for a program year. The transitional jobs covered by this cap are 1 time-limited work experiences that are wage-paid and subsidized and are in the public private or nonprofit sectors for individuals with barriers to employment who are chronically unemployed or have an inconsistent work history 2 to be combined with comprehensive employment and supportive services and 3 are designed to assist eligible participants to establish a work history demonstrate success in the workplace and develop the skills that lead to entry into and retention of unsubsidized employment. Incumbent Worker Training Expenditures A new Incumbent Worker Training Expenditures reporting line item was added to the Local Adult and Local Dislocated Workers 9130 reports in accord with WIOA sec. 134 d 4 A i which sets a cap for these expenditures of twenty percent of 10 the amount of Federal funds allocated to a local area to carry out the Adult and DW programs for a program year. Note WIOA sections 134 d 1 A iii 134 d 4 A i and 134 d 5 allow a local area to combine their Local Adult and Local Dislocated Worker allocations to meet the specified expenditure cap for each of the following activities Pay-for-Performance Contracts Transitional Jobs and Incumbent Worker Training. For example a local area receives 1.5 million in Adult funds and 1.0 million in DW funds. It may use up to 250 000 10 of the total for Transitional Jobs. Expenditure rates are calculated by dividing the sum of the cumulative expenditures for each applicable reporting line item for both the Local Adult and Local DW fund streams by the sum of the Total Federal Funds Authorized for the Local Adult and Local DW fund streams. Example for Transitional Jobs Expenditure Rate Calculation Sum of all PY and FY Local Adult Transitional Jobs Expenditures 11f entries Sum of all PY and FY Local DW Transitional Jobs Expenditures 11f entries Sum of all PY and FY Local Adult Total Federal Funds Authorized 10d entries Sum of all PY and FY Local DW Total Federal Funds Authorized 10d entries For the Local Youth allocations the cap for Pay-for-Performance contracts is tabulated separately from the Local Adult and Local DW allocations. B. Other Programs New Reporting Line Items ETA-9130 J and M NFJP Supportive Services Expenditures Supportive services are outlined in WIOA sec. 167 d as an allowable expenditure for eligible migrant and seasonal farmworkers. Program costs which are all other costs not defined as administrative WIOA sec. 3 1 must be classified and reported in the following categories Related assistance including emergency assistance Supportive services and All other program services. 11 Therefore a new Supportive Services Expenditures reporting line item was added to the National Farmworker Jobs Program ETA-9130 J report . TAA Training Expenditures A new Training Expenditures reporting line item was added to the Trade Adjustment Assistance Program ETA-9130 M . Training expenditures comprise the most substantial and important expenditure type of TAA program funds. The amount of funds expended on training services factors significantly in the formula required by regulations for determining annual funding allocations to states 20 CFR 618.910 through 618.940 . The addition of this data point reduces the effort required under the current collection by eliminating the need to isolate this information after the fact which creates burden on states for the purposes of auditing and validation procedures. Sec. 249B b 6 B of the Trade Act provides for the collection of data on spending including t he total amount of the payments to the States to carry out sections 235 through 238 used for training . 20 CFR 617.61 provides authority to collect data from states regarding activity for TAA requiring that state agencies administering the TAA program furnish to the Secretary such information and reports and conduct such studies as the Secretary determines are necessary or appropriate for carrying out the purposes of the Act and this Part 617. 7. Additional Guidance Regarding Pre-Existing Reporting Line Items. A. ETA-9130 Section 10 Transactions 10a Cash Receipts The amount entered in line 10a must not exceed the Total Federal Funds Authorized in line 10d. For Local Youth B Local Adult D and Local Dislocated Workers F 9130 reports Cash Receipts reported should reflect the State s receipt of cash to be disbursed to local areas to pay for allowable Local Youth Adult and Dislocated Workers costs associated with the funding authority identified on Line 10d Total Federal Funds Authorized . 10b Cash Disbursements The amount entered in line 10b must not exceed the Cash Receipts identified on line 10a. At the recipient level the term disbursement means the transfer of funds from the recipient to a subrecipient or other payee commonly by cash check voucher or credit card payment. Disbursements at the recipient level include electronic transfers of cash to a subrecipient organization and payments to contractors for goods and services. Examples of disbursements at the Federal level are on-line transfers to recipients through the HHS-PMS system. 12 For Local Youth B Local Adult D a nd Local Dislocated Workers F 9130 reports Cash Disbursements means cash disbursed by local areas from the cash received from the State. 10c Cash on Hand States must adhere to the rules for transferring funds between the Federal government and States f or Federal assistance programs in accordance with 31 CFR 205 . In accordance with 2 CFR 200.305 all recipients must minimize the amount of time between drawdowns and disbursements. An explanation for the excess cash on hand amount must be provided in the Remarks se ction of the financial report as appropriate . 10d Total Federal Funds Authorized The Total Federal Funds Authorized f or the WIOA Statewide Youth A Statewide Adult C Statewide Dislocated W orkers E Statewide Rapid Response H Local Yo uth B Local Adult D and Local Dislocated W orkers F 9130 report s are not prefilled but are components of States NOA s that are issued for the WIOA Youth Adult and Dislocated W orkers funding streams respectively . 10e Federal Share of Expenditures The OMB Uniform Guidance defines expenditures in 2 CFR 200. 34 . The amount entered in line 10e must not exceed the Total Federal Funds Authorized in line 10d. The total amount of expenditures reported on line 10e should generally exceed because of the amount of accruals and should not be less than the amount reported in Cash Disbursements 10b . If ETA reviewers observe that the amounts reported in Federal Share of Expenditures 10e and Cash Disbursements 10b are consistently the same it is an indication that the recipient is not reporting on an accrual basis. For the Local Youth B Local Adult D and Local Dislocated Workers F 9130 report s this entry represent the aggregate of accrued expenditures cash disbursements plus accruals incu rred for allowable Local Youth Local Adult and Local Dislocated W orker program activities. The local area expenditures are aggregated by the state and reported on line 10e. 10f Total Administrative Expenditures Recipients are advised to refer to the ap propriate program rules regulations and or grant award terms and conditions for specific definitions and or limita tions on administrative costs. Some grants may be identified in the grant agreement as exempt from breaking out administrative costs. In t his instance enter zero 0 in line 10f. For WIOA more information on what constitutes administrative costs may be found in WIOA sec. 3 1 . 13 For the Local Youth B Local Adult D and Local Dislocated Workers F 9130 reports this entry should inc lude the aggregate of accrued expenditures incurred cash disbursements plus accruals for allowable administrative activities at the local level for which administrative costs must be reported and then aggregated by the state. 10g Federal Share of Unliqu idated Obligations The OMB Uniform Guidance defines obligation in 2 CFR 200.71. In summary obligation is a term that references actions where a legal commitment to pay exists. The obligation may occur at the time the services are rendered or before s ervices are rendered when a binding agreement has been entered into. Examples of obligations or legal commitments include subgrant agreements purchase orders or cash disbursements. Obligations are not projected staff time future or projected rent pa yments future or projected training or items that are budgeted during the period of the grant award. In summary obligations are not plans budgets or encumbrances. For the Local Youth B Local Adult D or Local Dislocated Workers F 9130 report s the Federal Share of Unliquidated Obligations represents obligations incurred against local area Youth Adult or DW funds for which an accrued expenditure has not yet been recorded or an outlay disbursement made in the local areas official accounting records. States should not record the annual amount allotted to each local area as an obligation on this report. On the Closeout ETA -9130 report this line item should be zero 0 . 10h Total Federal Obligations No entry is required of recipients as thi s reporting line item is a system calculated field Federal Share of Expenditures 10e plus Federal Share of Unliquidated Obligations 10g . A hard edit prevents this entry from exceeding the Total Federal Funds Authorized 10d . For the Local Youth B Local Adult D and Local Dislocated Workers F 9130 report s the Federal Share of Obligations represents obligations incurred against local area Youth Adult or D W funds for which an accrued expenditure has not yet been recorded or an outlay disbur sement made in the local entities official accounting records. States should not record the annual amount allotted to each local area as an obligation on this report. 10j Total Recipient Share Required Match as applicable to ETA grant programs is defi ned and discussed in the OMB Uniform Guidance at 2 CFR 200.29 and 2 CFR 200.306 . The data reported on this line is the total amount of non -Federal funds mat ch required during the period of performance of the grant to support the objectives of the subjec t award . Match may be required either by statute or within the grant agreement as a condition of funding. 14 All matching funds must be spent on allowable grant activities and in accordance with the cost principles contained in the Uniform Administrative R equirements Cost Principles and Audit Requirements for Federal Awards at 2 CFR Part 200 and the Department s exceptions at 2 CFR Part 2900 . The recipient cannot claim a cost as both an allowable cost to be reimbursed from grant funds and as a match ex penditure. Match must be expended within the period of performance. For funds reported on the Basic 9130 and on the Senior Community Service Employment Program K ETA -91 30 report there is no entry required in line 10j as this reporting line item is pr e-filled automatically by the reporting system. There is no statutory requirement for match under WIOA with the exception of the employer non -federal share requirement for Incumbent Worker Training. Therefore line 10j will always be zero 0 on all St atewide Youth A Statewide Adult C and Statewide Dislocated Workers E 9130 report s as well as the Local Youth B ETA - 9130. Per WIOA sec. 134 d 4 C states must report employers share of the costs of Incumbent Worker Training on the Local Adu lt D and Local Dislocated W orkers F 9130 reports. 10k Recipient Share of Expenditures Expenditures reported in this entry must occur within the grant s period of performance and must meet the definition in 2 CFR 200.306 b . There are two types of re cipient share expe nditures reported on line 10k match and other non -Federal leveraged resources. To be reported on this line the expenditures must be those which could otherwise have been paid for out of subject grant funds. There are two types of matc h expenditures cash and third party in -kind contributions. Cash match reflects additional funds or services allowable costs provided and paid for by the recipient and or any subrecipient from non -Federal funds that are in support of grant objectives an d outcomes. Cash match may also include unreimbursed allowable indirect costs but are subject to the administrative cost limitation. The value of the cash match is the actual costs incurred as reflected in the recipient s accounting system. In order to qualify as match the costs cannot have been paid from Federal funds may not have been charged to program income or used to match other Federal match requirements nor have been for costs that are unallowable. Third party in -kind contributions are the products space or services provided by a third -party organization and not paid for by the recipient or a subrecipient but which would represent allowable costs if paid for with grant funds. These contributions must support allowable grant activity and outcomes. The rules that apply to determining the valuation of in -kind contribution s have been updated and can be found at 2 CFR 200.306 and 2 CFR 200.434. Other Federal funds expended for the purpose and benefit of this grant should be included in line item 11a Other Federal Funds Expended . 15 B. ETA -9130 Section 11 Additional Data Required Refer to the appropriate program rules and regulations and or grant award terms and conditions for specific reporting guidelines. C. ETA -9130 Section 12 Remarks This sec tion provides an opportunity to outline any explanations and or details deemed necessary by the recipient or information required by ETA. Additional information may also be required as part of a special condition or term to a grant award . As outlined in TEGL 12 -14 Allowable Uses and Funding Limits of Workforce Investment Act WIA Program Year PY 2014 funds for Workforce Innovation and Opportunity Act WIOA Transitional Activities and the corresponding Frequently Asked Questions FAQs expenditures for activities to facilitate the transition from WIA to WIOA must be reported in this section. Both the TEGL and FAQs are available on ETA s official website for WIOA at http www.doleta.gov wioa . 8. Transition to the New Forms . Revised ETA -9130 Forms and Instructions were made available for public comment as required by the Paperwork Reduction Act PRA in a 60 - day Federal Register Notice published at 80 FR 46337 on A ugust 04 2015 and a 30 -day notice publis hed at 80 FR 80815 on December 28 2015 . OMB approved the new ETA -9130 Financial Reports on April 13 2016 OMB Control No. 1205 -0461 extending the expiration date through April 30 2019. The new forms and instructions are available at https doleta.gov grants financial reporting.cfm . Given the mid -April approval date ETA understands that it is not feasible for recipients to implement the new requirements for the financial reporting q uarter beginning on April 1 2016 and ending on June 30 2016. Instead implementation is expe cted with the financial reporting quarter beginning on July 1 2016 and ending on September 30 2016. This allows recipients adequate time to prepare their acco unting and reporting systems for the change. It is imperative that recipient staff across all functions e.g. program grant implementation performance reporting financial etc. have a thorough understanding of the requirements set forth in this guida nce and work in unison towards the seamless design and maintenance of an accurate and reliable financial reporting system to successfully implement financial reporting requirements of WIOA and to align the financial reporting with the OMB Uniform Guidance. 9. Effective Date and A ction Requested . Grant r ecipients will be required to submit their financial information using the new ETA -9130 Financial Reports for all reporting periods beginning with the quarter ending on September 30 2016 . This is required fo r all existing and new awards. All pre -existing and new reporting line items must be reported cumulatively from grant inception . Previous old er versions of ETA -9130 Financial Reports that were submitted by grantees will remain available for the quarter s ending June 30 2016 or earlier . Please disseminate this guidance to all staff directly and indirectly responsible for financial management and reporting of ETA grants and cooperative agreements. 16 10. Inquiries . Questions regarding this guidance should be directed to the appropriate Regional Office.