TEGL_31-14_Acc.pdf

ETA Advisory File Text

ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 31-14 TO STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS STATE AND LOCAL WORKFORCE BOARDS AND CHAIRS STATE LABOR COMMISSIONERS WIA SECTION 166 INDIAN AND NATIVE AMERICAN PROGRAM GRANTEES FROM PORTIA WU s Assistant Secretary SUBJECT Sector Partnership National Emergency Grants 1. Purpose. To announce the availability of up to 150 million for Sector Partnership National Emergency Grants SP NEGs . 2. References. Workforce Innovation and Opportunity Act WIOA section 170 Public Law Pub. L. 113-128 enacted July 22 2014 Workforce Investment Act of 1998 WIA section 173 29 U.S.C. 2918 WIA regulations at 20 CFR part 663 and 671 Training and Employment Guidance Letter TEGL No. 16-03 National Emergency Grant NEG Policy Guidance dated January 26 2004 TEGL No. 16-03 Changes 1 2 4 and 5 National Emergency Grant NEG Policy Guidance Workforce Investment Act National Emergency Grants Application Procedures 69 Federal Register Notice 23052 April 27 2004 Information Collection Forms ETA 9103 9104 9105 9106 9107 OMB Control No. 1205-0439 ETA Form 9090 and the Workforce Investment Act Standardized Record Data WIASRD format OMB Control No. 1205-0420 and ETA Form 9130 OMB Control No. 1205-0461 RESCISSIONS None EXPIRATION DATE Continuing EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION WIA National Reserve CORRESPONDENCE SYMBOL OWI DATE April 29 2015 2 TEGL14-03 Performance Reporting Submission Procedures for the Workforce Investment Standardized Record Data WIASRD and the Annual Report under Title IB of the Workforce Investment Act WIA dated November 13 2013 Training and Employment Notice TEN 32-10 Revised National Emergency Grant Application Submission and Review Process dated March 30 2011 TEGL No.10-09 Implementing Priority of Service for Veterans and Eligible Spouses in all Qualified Job Training Programs Funded in whole or in part by the U.S. Department of Labor DOL dated November 10 2009 TEGL 22-04 Serving Military Service Members and Military Spouses under the WIA Dislocated Worker Formula Grant dated March 22 2005 TEGL 15-10 Increasing Credential Degree and Certificate Attainment by Participants of the Public Workforce System Dated December 15 2010 2 CFR Part 180 29 CFR Part 98 ETA Sector Strategies Framework http businessengagement.workforce3one.org resources files sector-strategies- framework . 3. Background. NEGs are discretionary grants awarded by the Secretary of Labor under section 173 of WIA 1 to provide employment-related services for dislocated workers. NEGs provide resources to states and other eligible applicants to respond to large unexpected layoff events causing significant job losses. This funding is intended to temporarily expand capacity to serve dislocated workers and meet the increased demand for employment and training services with the goal of quickly reemploying laid-off workers and enhancing their employability and earnings. Qualifying layoff events include plant closures and mass layoffs as well as other events recognized by the Secretary. Most provisions of WIOA are scheduled to take effect on July 1 2015 and the Department of Labor the Department or DOL intends for this funding to be used consistent with WIOA s requirements. The Department will issue additional Operating Guidance for WIOA administration before the July 1 2015 implementation date of the new law. This Operating Guidance will address a range of topics including services for dislocated workers. Despite recent employment growth many states continue to experience a number of smaller dislocation events that occur over time and an ongoing lag in reemployment for long-term unemployed workers. These dislocation events add to the already significant number of long- term unemployed individuals who have been jobless for 27 weeks or more and who represent 30 percent of all unemployed persons according to the Bureau of Labor Statistics. 2 1 Under WIOA the relevant provision is found at section 170 on National Dislocated Worker Grants. The terms of WIOA section 170 that address economic dislocations are substantively the same as the terms of WIA section 173. Although these grants are authorized under WIA grantees are to administer these SP NEGs consistent with the requirements and services of WIOA. This is consistent with the Department s transition authority under Section 503 of WIOA which authorizes the Secretary of Labor to take such actions as the Secretary determines to be appropriate to provide for the orderly transition from the WIA to any provision of Title I of WIOA. 2 http www.bls.gov news.release empsit.t12.htm 3 The Secretary recognizes the impact of these layoffs across the nation as a significant dislocation event for purposes of NEG assistance. These circumstances have strained the workforce investment system s ability to provide crucial training and reemployment services to improve dislocated workers employment prospects. Analysis of program and administrative data has demonstrated that the system s response to this strain in resources has been a decline in the intensity of services provided despite the fact that participant levels remain at near historic highs. From PY 2010-2013 3 individuals receiving core services declined by 12 percent while individuals receiving intensive services declined by 49 percent. According to DOL performance data individuals who receive more intensive levels of services have greater success in finding employment in the Dislocated Worker program individuals who received intensive services had a 64.7 percent entered employment rate EER compared to a 54.8 percent EER for those who received only core services in PY 2013. 4 These individually tailored services are shown to help dislocated workers find work align their skills with in-demand occupations and identify occupational requirements where additional training may be needed. Such services are also more effective in meeting the needs of the many businesses that are having difficulty finding and hiring workers with the right skills for jobs they need to fill. To support an American economy that provides opportunity for all workers must have skills that align with the needs of businesses and must be readily able to adapt as business needs evolve. States and local areas are strategically positioned to support a job-driven approach to workforce development through sector partnerships and sector strategies. Sector strategies are regional industry-focused approaches to workforce and economic development that improve access to good jobs and increase job quality in ways that strengthen an industry s workforce. These strategies bring together partnerships among businesses training providers labor unions community organizations workforce development organizations and other key stakeholders around specific industries to address the workforce needs of both businesses and workers. Eligible dislocated workers generally have a strong connection to the workforce but may not return to their previous industry or occupation. Partnerships across growing and in-demand industries can support dislocated workers to translate their skills into new sectors identify the training they need to succeed in a new industry and acquire the necessary skills for this transition. Sector-based approaches can provide businesses with the skilled workforce they need and dislocated workers with new skills credentials and careers where they can succeed. Sector partnerships are fundamental to effective sector strategies and the Department has structured the SP NEGs opportunity to advance and complement the more integrated and comprehensive dislocated worker services envisioned by WIOA. The SP NEGs are intended to provide new services and flexibilities that can be integrated with WIOA not simply to 3 PY 2010 2011 2012 and 2013 WIASRD Databooks http www.doleta.gov performance results pdf py 2010 wiasrd data book.pdf http www.doleta.gov performance results pdf py 2011 wiasrd data book.pdf http www.doleta.gov performance results pdf PY2012WIASRDDataBook.pdf http www.doleta.gov performance results pdf PY 2013 WIASRD Data Book.pdf 4 National Summary of Annual Performance Data PY 2013 4 supplement or replenish regular WIA Dislocated Worker formula funds. The specific activities targeted by these grants serving dislocated workers include regional sector planning and strategies enhanced career services to dislocated workers and work-based training opportunities. 4. Eligible Participants. Dislocated workers are eligible participants in SP NEGs. Generally a dislocated worker is an unemployed individual with previous attachment to the workforce who was laid off. For a full definition of dislocated worker eligibility see WIOA section 3 15 . States or other eligible entities should use labor market information to appropriately target outreach and services to dislocated worker populations including dislocated workers that may have additional barriers or challenges to reemployment such as long-term unemployed jobseekers unemployed for at least 27 weeks in aggregate over the past year Unemployment Insurance claimants profiled as likely to exhaust their benefits and foreign- trained workers that have faced barriers to obtaining employment in their field or profession. States or other eligible entities identifying targeted dislocated worker populations should use labor market and administrative data to clearly establish the need for such targeting. Similar to other ETA-funded programs veterans will receive Priority of Service for training and services made available under SP NEGs as required by the Jobs for Veterans Act and described in TEGL 10-09. As clarified in TEGL 22-04 separating service members are generally considered to have satisfied the termination component of the WIA definition of a dislocated worker. Therefore as long as a separating service member satisfies the other criteria for dislocated worker eligibility including the requirement that the individual is unlikely to return to a previous industry or occupation he or she would generally be an eligible dislocated worker under SP NEGs. Coordination with intensive and case management services that are provided to unemployed post-9 11 era veterans are strongly encouraged. 5. Eligible Applicants and Application Requirements. Eligible applicants are 1. The state agency responsible for administering WIA title I activities including those in outlying areas. 2. Entities eligible to receive funding under section 166 of WIA. States or other eligible entities must partner with local area Workforce Investment Boards or local Workforce Development Boards as Workforce Investment Boards have begun to transition to WIOA which may be clustered to align with regional areas on grant activities including regional planning efforts sector strategies and enhanced dislocated worker services. 5 Applicants must address the following in their application narrative Partnerships Applicants must address partnerships the applicant has or will create with local area Workforce Investment Boards or Workforce Development Boards to conduct the planned grant activities including the regional planning efforts and sector strategies and the delivery of enhanced dislocated worker services. Applicants also must identify current or targeted multiple at least three employer partners that represent a significant percentage of the jobs in the sector of focus which will be engaged in proposed sector strategies regional planning and or work-based learning activities. In-Demand-Occupations Proposed strategies should be developed around activities that ultimately result in employment in in-demand occupations that have been identified using available labor market information. Applicants must identify these targeted occupations or industries. Regional Planning and Strategies - Up to 25 percent of total funds but not more than 500 000 One of the Employment and Training Administration s ETA priorities is to increase the number of states and regions that actively participate in regional planning and regional industry-focused approaches to workforce and economic development that are commonly referred to as sector strategies. Regional planning and strategies support dislocated workers by assessing the regional economic landscape to identify new or growing employment opportunities in the region. They also help ensure partnerships and regional assets from the workforce investment system industry community colleges labor unions nonprofits and other stakeholders are aligned and integrated under strategies that can be used to respond to economic shocks such as plant closings natural disasters and long-term unemployment within the regional workforce. Sector Strategies represent a strategic and demand-driven way for workforce organizations to conduct business moving from a program administration focus to a more proactive role building regional talent pipelines addressing skill shortages and creating meaningful career pathways for a range of workers in important regional industries. A demand-driven full-scale sector strategy means putting the business community in the middle and thinking more broadly about what a workforce organization or intermediary can do to help businesses thrive and grow beyond simply placing workers in jobs and arranging training resulting in the provision of new employment opportunities for dislocated workers. Dislocated workers generally have a successful work history and have lost their employment through no fault of their own. These dislocations are caused by economic disruptions industry decline or a change of the type of workforce the business needs. Dislocated workers are unlikely to find work in their previous occupation or industry and could benefit greatly by receiving services that are strategically aligned with sector strategies and industry 6 partnerships. States that have robust sector strategies in place are able to align resources to address the skills and other requisite needs of in-demand industries. Recognizing WIOA s emphasis on regional planning and sector strategies and the benefits these activities can provide in better serving job seekers including dislocated workers a portion of the SP NEG must be used to fund activities that support regional planning and sector strategies. These activities may support the development of new strategies or updates and expansion of preexisting plans and strategies. Allowable uses of funds include but are not limited to Partnership and program development with stakeholders employers apprenticeship programs etc. o Including convening among regional partners employers or other stakeholders Acquisition analysis and utilization of workforce information to identify regional trends including but not limited to labor market information and other state or private data. Asset mapping and other analysis such as Strength Weaknesses Opportunities and Threats SWOT analysis Developing regional plans Training for staff in State and local areas necessary to facilitate regional planning and implement regional strategies Establishing social and or peer learning networks among regions using sector strategies Identifying and mapping the necessary skills and competencies for in-demand jobs o Assessing how well those skills and competencies are reflected in existing training programs and curricula o Identifying aligned industry credentials for those skills and competencies needed Employers regional industry representatives and national industry representatives if applicable should be actively engaged in designing and implementing the sector strategy in five key areas 1 serving on the project s leadership team 2 helping implement program strategies and goals 3 identifying and mapping the necessary skills and competencies for the program s 4 assisting with curriculum development and designing the program and 5 where appropriate assisting with the design of an assessment or credential that will address industry skill needs. The planning component of the grant will take place simultaneously with training and other service delivery activities. Up to 25 percent but not more than 500 000 of the total funds may be used for regional planning activities. The applicant must describe how the funds will be used for planning and provide ETA with copies of any regional plans or other related grant products as a result of these funds upon completion of the grant. 7 Program Services ETA is interested in funding programs that can effectively recruit and serve a range of dislocated workers and are built around a comprehensive up-front assessment of participant skills relative to those required for employment and provide customized interventions across three tracks 1 re-employment services such as comprehensive skills assessments intensive coaching relocation assistance and other short-term specialized services culminating in direct job placement 2 short-term training and work-based learning opportunities such as OJT leading to employment and 3 accelerated skills training with a focus on work-based training that leads to industry-recognized credentials and employment such as registered apprenticeship. ETA is particularly interested in programs that coordinate closely with Unemployment Insurance UI programs to ensure UI claimants individuals who have exhausted UI benefits and other dislocated workers encountering long-term unemployment are provided intensive staff assisted counseling reemployment services and assessments to help them navigate entry into new careers. SP NEG Program Services are categorized into two categories 1. Enhanced Career Services to Dislocated Workers and 2. Training and Work-Based Training Models Enhanced Career Services to Dislocated Workers At least 20 percent of total funds The enhanced dislocated worker services career services provide the workforce system the opportunity to build on a customer-focused approach to service delivery. This opportunity is designed to provide dislocated workers with the range of services training and job placement assistance they need to fill middle and high-skill jobs in identified high demand sectors. Many of these workers may require re-employment services such as career coaching and assistance in adapting their skills and experience to new industries while others at lower skill levels may benefit from short-term and even longer-term training to obtain jobs that can match their previous earnings. These workers may require targeted and customized employment assistance and counseling training and other specialized service interventions to succeed in the labor market as rapidly as possible. These SP NEGs will be administered consistent with WIOA which allows greater flexibilities in providing services to dislocated workers through career services. Applicants must describe the types of career services consistent with WIOA and applicable state and local policies to be undertaken in their proposal which include Short-term prevocational services including o Development of learning skills o Communication skills o Interviewing skills o Punctuality o Personal maintenance skills o Professional conduct skills 8 Internships or work experiences that are linked to careers Out-of-area job search assistance and relocation assistance including the development and planning of policies for the provision of these services English-language acquisition programs in coordination with other activities as appropriate for individuals to obtain unsubsidized employment Comprehensive and specialized assessments of the skill levels and service needs of adults and dislocated workers which may include o Diagnostic testing and use of other assessment tools and o In-depth interviewing and evaluation to identify employment barriers and development of individual employment plans Career planning job coaching and job matching services Identification of appropriate training programs Job development and placement Provision of referrals to and coordination with other programs and services. ETA is interested in applications that make available these new career services allowed under WIOA particularly focusing on more intensive services that have been reduced in recent years. Applicants are encouraged to develop policies in the provision of these services that also can be used to inform and support the implementation of WIOA policies in serving dislocated workers. Investments in technology enabled tools to support better skills assessments and job matching is allowed under the SP NEG. Training and Work-Based Training Models - At least 30 percent of total funds Similar to the Dislocated Worker Training DWT and Job-Driven JD NEGs a key component of the SP NEGs will be training with an emphasis on work-based learning models which research has shown to be effective in helping jobseekers to quickly reenter the workforce learn the desired skills in the workplace and obtain or retain employment utilizing the newly acquired skills and competencies. Applicants must discuss and provide a rationale for the types of work-based learning to be undertaken under the SP NEGs. Allowable training and work-based strategies under the SP NEGs are consistent with the expanded strategies authorized by WIOA and include Increasing the use of On-the-Job Training consistent with WIOA Development and provision of transitional job opportunities and policies Development and provision of Incumbent Worker Training IWT opportunities and policies that provide underemployed dislocated workers with opportunities for advancement and wage gains within their company or used to avert layoffs. IWT must include matching resources from the employer which may include the wages of the 9 participant paid by the employer while in the training. The employer match may be provided in cash or in-kind. Pre-apprenticeship training for dislocated workers with linkages to Registered Apprenticeships Referrals and support in placing participants into Registered Apprenticeship programs including development of policies for use of individual training accounts ITAs and supportive services to support participation in these programs Development of customized cohort-based training to meet the needs of employers Development and provision of work support activities for workers with barriers to employment while in training including low-wage workers and workers with disabilities such as supportive services activities during non-traditional hours assistive technology benefits planning and the inclusion of onsite child care while participating in these activities Update curricula and train faculty in existing programs to be better aligned with employer needs Invest in transitioning to competency-based training strategies that result in stackable and or latticed credentials that are industry recognized A minimum of 30 percent of the total funds must be used for one or more of the training and work-based training models identified in the application narrative. Selected work-based training models must comply with the following requirements OJT opportunities and customized training must be provided under a contract with an employer in the private-nonprofit or for-profit sector o Credential attainment is not required to be a part of OJT and OJT will continue to be exempt from the Department s credential measure. However grant recipients are strongly encouraged to prioritize OJT opportunities to include a formal training component that leads to a credential o The parameters associated with OJT in ETA s current OJT NEG guidance TEGLs 4-10 and 16-12 apply to any OJT opportunities offered under the SP NEGs notwithstanding the definition of prolonged unemployed contained in these guidance documents and the OJT reimbursement rate allowed in TEGL 4-10 o Consistent with WIOA the application should identify the wage cap for OJT. Generally it is 50 percent however the Governor or local board may increase it to 75 percent based on certain factors. If seeking an increase in the wage cap to 75 percent the application should identify the factors it is using to make the determination they may include Participant characteristics Size of the employer or employers 10 Quality of the employer-provided training as well as any advancement opportunities for participants Other factors identified in the application Although the purpose of the SP NEGs is to provide support for dislocated workers who are currently unemployed a portion of available funding may be used for incumbent worker training IWT strategies for underemployed workers i.e. workers who would prefer full-time work but are working part-time for economic reasons. While these workers are employed they have experienced a reduction in hours or a previous dislocation that has led them to accept reduced employment and often lower wages that may have a permanent effect on their careers. IWT strategies if proposed by the applicant must be described in the application narrative. These strategies must focus on increasing skills for underemployed frontline workers in an effort to advance these workers to more skilled positions with the same employer or industry sector leading to an increase in earnings through more work hours or an increase in pay. Once these workers advance the employer must provide an opportunity to the local service provider to fill this now vacant position with a local dislocated worker. As part of the Incumbent Worker upskilling strategy applicants must describe their upskill backfill strategy in their application narrative. IWT training must be provided under an agreement with an employer in the private-nonprofit or for-profit sector. In addition o Not more than 10 percent of the total funds may be used for Incumbent Worker training o Incumbent Worker training must have an employer match based on the size of the company. Wages paid to the participant while in training can be included as part of the match. The matching requirements are as follows At least 10 percent of the cost for employers with 50 or fewer employees At least 25 percent of the cost for employers with 51 to 100 employees At least 50 percent of the cost for employers with more than 100 employees Transitional jobs opportunities must be provided under a contract with an employer in the private non-profit or for-profit sector as well as non-federal public sector employers. Transitional jobs are time-limited work experiences that are subsidized for individuals with barriers to employment who are either chronically unemployed long-term unemployed or have an inconsistent work history. Successful transitional jobs strategies often include partnerships with other programs such as TANF. If transitional jobs are part of the proposal they should be described in the application narrative. o Not more than 10 percent of the total funds may be used for Transitional Jobs described in the application narrative For non-work-based training project operators must limit the training opportunities provided to training providers listed in their Eligible Training Provider List ETPL as proposed training programs must have demonstrated success in serving the targeted 11 population. Additionally project operators should give preference to competency-based education and training that result in stackable industry-recognized credentials. Alignment and Coordination with Other Resources Applicants must describe how they will deliver services in coordination with at least two other federal state or local resources which can include but are not limited to Unemployment Insurance Wagner-Peyser Employment Service WIA WIOA Adult and DW programs Trade Adjustment Assistance State Apprenticeship Agencies Jobs for Veterans State Grants Homeless Veterans Reintegration Program Career and Technical Education programs Authorized under the Carl D. Perkins Career and Technical Education Act. Employment and Training Activities carried out under the Community Service Block Grant Act Adult Education and English for Speakers of Other Languages ESOL Vocational Rehabilitation Services Temporary Assistance for Needy Families TANF Supplemental Nutrition Assistance Program SNAP Employment and Training Economic development such as Manufacturing Extension Partnerships Transportation infrastructure such as Transportation Investment Generating Economic Recovery TIGER grants and Innovative Public Transportation Workforce Development Program Ladders of Opportunity Initiative Child Care and Child Support programs operated at the state or local level State Medicaid Programs Other Federal agency supported job-driven workforce development initiatives under the Departments of Transportation Energy Veterans Affairs Housing and Urban Development Interior Health and Human Services and Defense programs Coordination with these programs may include the leveraging of funds participant referrals co-enrollment or other demonstrated formal partnerships including planning and the development of formal agreements for service delivery . In addition to public funding streams applicants are also encouraged to leverage resources and activities with relevant philanthropic and community-based organization efforts in their target communities. ETA is interested in proposals that build upon existing partnerships with particular interest in proposals that build new sustainable partnerships. 12 Administrative Costs Up to 10 percent of total funds Up to 10 percent of the funds may be used for administrative costs associated with operating the grant at the state and project operator levels. The applicant must describe how the 10 percent available for administrative activities will be distributed between the state and local project operators. Evaluation Applicants must acknowledge in their application that they understand that ETA may conduct an independent evaluation of the outcomes and benefits of these NEGs and by accepting a SP NEG award agree to participate in such an evaluation. 6. Use of Funds. Applicants must address the following parameters in their narrative as well as complete the budget forms that are part of the application process described in Section 6 that show the requested funding being distributed according to these parameters. The percentages outlined represent that maximum or minimum levels for each category of services applicants must customize the percentages to meet their specific needs. SP NEG Activity Allowable Percentages of Total Grant Funds Regional Planning Up to 25 percent but no more than 500 000 Program Services At least 5 0 percent Enhanced Services for Dislocated Workers At least 20 percent Work -based Training Models At least 30 percent Not more than 10 percent of total grant funds may be used for IWT Not more than 10 percent of total grant funds may be used for Transitional Jobs Administrative Costs Up to 10 percent 7. Awards. Based on the amount of funds that will be available for SP NEGS the Department intends to make awards that range between 500 000 and 7 million. Awards will take into consideration economic and labor market need as described in the application narrative. We may also consider grantee capacity and previous grantee performance. 8. Funds Availability. These funds will be available for expenditure from the date of award prior to June 30 2015 through June 30 2017. However the Department reserves the right to provide period of performance extensions beyond this date as it deems appropriate and necessary to achieve the purposes of these awards. 13 9. Application Process for SP NEGs. Applications for SP NEGs are to be submitted via the NEG Electronic Application System eSystem . Applications must be received by 11 59 PM EDT on May 29 2015 to be considered for funding. NEGs are listed in the Catalog for Federal Financial Assistance under 17.277 and are funded by the Employment and Training Administration. This Training and Employment Guidance Letter serves as the announcement for a new funding opportunity FOA-ETA-15-09 Sector Partnership National Emergency Grants. The application must contain A SF-424 OMB No. 4040-0004 A SF-424A OMB No. 4040-0006 A Project Synopsis Form 9106 OMB No. 1205-0439 A Planning Form Form 9103 OMB No. 1205-0439 with projected enrollment and expenditure information. Work-based learning activities should be included under the existing OJT fields. A brief narrative that addresses the items discussed in Section 5 above OMB No. 1205- 0439 including the funding parameters contained in the Use of Funds portion of this section. A typical narrative should be no more than 15 pages in length double spaced . Note Work-based learning activities should be included in the grant application under the existing OJT fields. All applications received by the closing date will be given an initial review for completeness by the Grant Officer prior to being provided to panel reviewers to assess and rate the technical merit and responsiveness of each application. The technical merit review panel will carefully evaluate the applications against the criteria outlined in this TEGL to determine the merits of each application. These criteria are based on the policy goals priorities and emphases set forth in this TEGL. The technical merit review panel results will serve as the primary basis for selection of applications for funding however the panel results are advisory in nature and not binding on the Grant Officer. The Grant Officer reserves the right to make selections based solely on the final scores or to take into consideration other relevant factors when applicable. Such factors may include the geographic distribution of funds and or other relevant factors. The Grant Officer may also consider any information that comes to his her attention. NOTE The Department will determine if the applicant had any restriction on spending for any ETA grant due to adverse monitoring findings within the past three years. Depending on the severity of the findings the Grant Officer may elect to not provide the applicant a grant award. ETA may elect to award a grant with or without discussions with the applicant. Should a grant be awarded without discussions the award will be based on the applicant s signature on the SF-424 including electronic signature which constitutes a binding offer by the applicant. All applications deemed to be responsive by the merit review panel will then go through a risk review process. Prior to making an award ETA will review information available through any Office of Management and Budget OMB -designated repository of government- wide eligibility qualification or financial integrity information such as the Federal Awardee 14 Performance and Integrity Information System FAPIIS Dun and Bradstreet and Do Not Pay. Additionally ETA will comply with the requirements of 2 CFR Part 180 codified at 29 CFR Part 98 Government-wide Debarment and Suspension Non-procurement . This risk evaluation may incorporate results of the evaluation of the applicant s eligibility application screening or the quality of its application merit review . If ETA determines that an entity is responsible and an award will be made special conditions that correspond to the degree of risk assessed may be applied to the award. Risk-related criteria to be evaluated include 1 Financial stability 2 Quality of management systems and ability to meet the management standards prescribed in the Uniform Grant Guidance 3 History of performance. The applicant s record in managing awards cooperative agreements or procurement awards if it is a prior recipient of such Federal awards including timeliness of compliance with applicable reporting requirements and if applicable the extent to which any previously awarded amounts will be expended prior to future awards 4 Reports and findings from audits performed under Sub-part F Audit Requirements of the Uniform Grant Guidance or the reports and findings of any other available audits and monitoring reports containing findings issues of non-compliance or questioned costs 5 The applicant s ability to effectively implement statutory regulatory or other requirements imposed on recipients. 10. Performance and Fiscal Reporting for SP NEGs. To ensure ETA is able to assess the success of these SP NEGs and other WIA and WIOA programs the collection of accurate quality data is a critical component of financial and performance accountability. To satisfy statutory and regulatory recordkeeping and reporting requirements states and other entities must report characteristics services received and outcomes of participants served with WIA and WIOA funds including these SP NEGs. Such information is necessary to determine the success of these investments. The following performance and fiscal reports are required ETA 9090 WIA Quarterly Report OMB Control No. 1205-0420 Workforce Investment Act Standardized Record Data WIASRD Quarterly Submission OMB Control No. 1205-0420 ETA 9130 U.S. DOL ETA Quarterly Financial Status Report OMB 1205-0461 ETA 9104 NEG Quarterly Performance Report QPR OMB 1205-0439 States must submit the WIASRD quarterly on all participants and exiters from SP NEGs. All relevant WIASRD data elements must be completed. An explanation of some of the particularly important elements follows 15 WIASRD data items 923 and 924 1st and 2nd NEG Project IDs which make it possible to isolate the individuals who were provided services through these SP NEGs from the general WIA WIOA DW population as well as other NEGs WIASRD data item 901 Date of Exit will be used in the calculation of SP NEGs outcomes In order to evaluate the success of SP NEGs it is imperative that states make every effort to submit the required reports on a timely basis and that they be accurate and complete. Individuals in OJT should not be included in the employment and credential attainment measure for the SP NEG program unless the OJT results in the attainment of a credential and subsequent employment. It should be noted that while the individual participating in OJT is not counted for performance under this measure the information on credential attainment for each individual must still be collected and reported in the WIASRD and submitted to ETA. The number of participants and exiters in the SP NEG must be included in the quarterly aggregate counts submitted by states in the ETA 9090 WIA Quarterly Report. States and other eligible entities also are encouraged but not required to develop other metrics and to provide the results in the comments section of their ETA 9104 submissions. States and other eligible entities might want to consider gathering information on provider and employer level characteristics services delivered and the number of long-term unemployed served. They also may wish to develop metrics that measure things such as initial employer involvement the depth of the employer s involvement and a demonstration of repeat usage of the workforce investment system by the employer. 11. Paperwork Reduction Act PRA Statement. According to the PRA no persons are required to respond to a collection of information unless such collection displays a valid OMB Control Number. The Department notes that a Federal agency may not conduct or sponsor a collection of information nor is the public required to respond to a collection of information unless it is approved by OMB under the PRA and displays a currently valid OMB Control Number 44 U.S.C. 3507 . Also notwithstanding any other provisions of law no person shall be subject to penalty for failing to comply with a collection of information if the collection of information does not display a currently valid OMB Control Number 44 U.S.C. 3512 . The currently valid OMB Control Number for this collection is OMB 1205- 0439. 12. Inquiries. Questions regarding this guidance should be directed to the appropriate ETA Regional Office. For more information about SP NEGs please visit http www.doleta.gov layoff .