TEGL 03-23.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION WIOA CORRESPONDENCE SYMBOL OWI- DYS DATE September 6 2023 RESCISSIONS None EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 03-23TO STATE AND LOCAL WORKFORCE AGENCIES STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS STATE-LEVEL EQUAL OPPORTUNITY OFFICERS AMERICAN JOB CENTER DIRECTORS ALL DEPARTMENT OF LABOR COMPETITIVE GRANTEES FROM BRENT PARTON Principal Deputy Assistant Secretary SUBJECT Allowable Uses of Funds f or Outreach Activities f or Federal Formula and Competitive Grant Awards 1.Purpose. This guidance 1 clarifies the allowable uses of Workf orce Innovation and Opportunity Act WIOA its successors and other competitive grant f unds f or outreach activities and 2 provides examples of how grantees can use grant f unds to ef f ectively and equitably conduct outreach to meet the needs of and better engage businesses and jobseekers. 2.Summary and Background. a.Summary This Training and Employment Guidance Letter TEGL aims to empower grantees to maximize the reach of workf orce development services by providing clarity on how f ormula and discretionary grant f unds can be used to conduct outreach activities. b.Background The public workforce system plays a critical role in connecting talent with opportunity connects diverse customers to employment and training opportunities and helps employers recruit skilled employees that match their employment opportunities. To f ully communicate the workforce system s value and expand awareness of its services to job seekers and employers the system must conduct ef f ective and targeted outreach. WIOA requires grantees to inf orm the public about services conduct proactive outreach to underserved populations and make individuals aware of services that can support their employment needs. The Unif orm Guidance regulates the administrative and f inancial requirements of federal grant f unds including WIOA f ormula grants and the Department of Labor s DOL competitive grants see 2 CFR part 200 and DOL s exceptions at 2 CFR part 2900. Specif ically 2 CFR 200.421 allows f or grantees to recruit program participants and to engage businesses by communicating with them. The American Job 2 Center AJC brand was created to increase awareness of the services of the public workf orce system and to f acilitate outreach. ETA hosted listening sessions where workf orce prof essionals requested additional technical assistance on the use of grant f unds f or allowable outreach activities including examples. In 2022 and 2023 ETA conducted webinars that provide examples of allowable outreach activities available at Workf orce GPS on the Outreach and Marketing f or the Public Workf orce Development System resource page.1 This TEGL seeks to demonstrate the f lexible uses of both f ormula and competitive grant f unds to conduct outreach activities and to empower the workf orce system to maximize its reach specif ically to those in underrepresented communities who are most in need of employment and training services. 3. Action Requested. ETA requests that state workf orce agencies state and local workf orce development boards and competitive grantees review revise or develop and implement policies and procedures that guide the allowable use of f unds to conduct outreach activities to meet program goals. 4. Allowable Outreach Activities. ETA encourages its grantees to conduct outreach activities to meet the needs of its customers and to f ulf ill grant objectives. In f act WIOA s Section 188 nondiscrimination and equal opportunity implementing regulations at 29 CFR 38.40 specif ically address the af f irmative outreach obligations of WIOA recipients. 29 CFR 38.40 states in pertinent part that recipients must take appropriate steps to ensure that they are providing equal access to their WIOA Title I-f inancially assisted programs and activities. These steps should involve reasonable ef f orts to include members of the various groups protected by these regulations including but not limited to persons of dif f erent sexes various racial and or ethnic national origin groups various religions individuals with limited English prof iciency individuals with disabilities and individuals in dif f erent age groups. In order to achieve this requisite component of af f irmative outreach the regulations contemplate a variety of outreach methods such as advertising the recipient s programs and or activities in the media such as newspapers or radio programs or sending notices about openings in the recipient s programs and or activities to schools or community service groups. Grantees may consider creating an outreach plan that details how the purpose of each outreach activity is linked to the program s objectives and indicators and how they would help meet perf ormance outcomes or program objectives. Part of a grantee s success and ability to meet expected perf ormance outcomes will depend on how well it communicates and promotes the benef its of the program s services to the communities it plans to serve. Grantees should make meaningf ul ef f orts to ensure outreach activities and or materials are 1 See https nextlevelnow.workforcegps.org resources 2023 05 25 21 11 Outreach-a nd-Ma rketing-f or-the-Public- Workf orce-Developm ent-System 3 inclusive of the community it is trying to recruit and serve. In addition to communicating with potential participants outreach strategies can include ef f orts to engage businesses. Grantees can engage in a variety of activities to ef f ectively conduct outreach to their customers and educate the public about the services. This TEGL aims to provide general guidance for both Federally formula-funded grantees and competitive grantees on how to assess whether certain outreach activities and uses of f unds may be allowable and to highlight the f lexibilities and opportunities that exist within current f unding. It is important to note that this TEGL does not provide an exhaustive list of allowable activities rather it gives examples of some of the more common allowable outreach activities. As with all Federal award costs grantees are encouraged to review the Cost Principles contained in 2 CFR 200.400 200.476 of the Unif orm Guidance. There you will f ind the basic criteria that must be met when charging costs to a Federal award--that such costs are necessary reasonable and allocable. Additionally grantees should review other relevant documents such as state policies and the grant s Statement of Work f or any grant-specif ic policies that govern outreach activities including the Steven s Amendment requirement see more inf ormation in Attachment I . Many grantees are party to Memoranda of Understanding MOU that contain the Inf rastructure Funding Agreements IFA that may also set out goals or limits to the costs that will be shared jointly by partners f or outreach activities. WIOA section 121 h 4 includes outreach costs in its def inition of infrastructure costs. Attachment I provides specif ic Unif orm Guidance statutory and regulatory language related to outreach. a. Defining Advertising and Public Relations A common misconception is that Federal workf orce development grant f unds cannot be spent on outreach such as advertising and public relations. These activities are not only allowable but are necessary to reach both businesses and jobseekers. The key is to make sure that the grantee is promoting Federally-funded activities services and programs and is not solely promoting the organization s name recognition or image. To apply the requirements in the Unif orm Guidance grantees should understand the def initions of advertising and public relations at 2 CFR 200.421. This dif ference is important as there are separate requirements that govern each type of activity. Advertising is an allowable cost and appropriate f or outreach f or grant activities services and programs as described in 2 CFR 200.421 b . Advertising is allowable through various media strategies such as print electronic digital radio social media billboards signage text apps and Quick Response QR code. Allowable activities include promoting program outreach and other specif ic purposes necessary to meet the requirements of the grant award. The media strategies used to conduct outreach to the public might be personnel or non-personnel costs and promote the activities of the Federal award. Grantees should ensure compliance with the regulations at 2 CFR 4 200.421 b and 200.421 e their grant award terms as well as the guidance in Attachment I of this TEGL. Public relations on the other hand includes activities that promote Federally-f unded activities services and programs and are typically personnel costs. Some public relations activities include but are not limited to attendance at f acilitation of collaboration with or participation in job career community f airs rapid response events one-stop satellite centers mobile one-stops community access points high school college career day podcasts and other interviews etc. While advertising of Federally-f unded activities services and program of f erings might be present at a public relations event public relations differs f rom advertising in that staff typically interact directly with the community public or press during public relations activities. Public relations are an allowable outreach cost f or grant activities services and programs. The Unif orm Guidance at 2 CFR 200.421 d describes allowable public relations activities and at 2 CFR 200.421 e lists unallowable public relations activities. This TEGL and its attachment provide examples of allowable public relations activities as well as general rules of thumb to apply when determining what public relations are allowable or unallowable. Grantees especially in AJCs may have MOUs that describe the combined costs f or advertising and public relations outreach that encompass the services offered by all its partners. Inf rastructure costs might include media platforms print electronic radio social media billboards signage text apps QR codes etc. describing one-stop partner activities services and programs. IFA costs may identif y instances and potentially additional associated costs f or supply purchase customization where these purchases are specif ic to grant outreach activities. ETA broadly interprets grant outreach activities that promote the activities services and programs of the grant award to mean ef f orts to educate enroll employ or extend ref errals to customers with interests in ETA s publicly-f unded workforce development system ef f orts. For example execution of this strategy might include supplies bearing the one-stop delivery identif ier at 20 CFR 678.900 as well as a QR code or website that is owned managed and updated by the grantee and or signatories to the MOU and directs the public to more inf ormation about the AJC and other workf orce programs. b. General rules of thumb The Unif orm Guidance regulations and this guidance will not necessarily list every possible scenario. The Uniform Guidance generally governs the administrative and f inancial uses of f unds. Grantees and their f iscal teams should be f amiliar with those requirements. The f irst step in assessing if a cost is an allowable cost to an ETA grant is to determine if the cost is necessary. Some questions to consider are Is this cost necessary f or the perf ormance of the grant Will this cost assist the organization in achieving its grant s outcomes and goals 5 Another step in assessing an allowable cost to an ETA grant is reasonableness. When testing f or reasonableness of a cost consider the prudent person theory. In the prudent person theory your organization must consider Would a prudent person use Federal f unds to purchase such items Would you have used your own f unds to purchase such items Do internal controls MOU IFA policies sub-recipient agreements contracts etc. exist that designate describe outreach activities and or limits Is the ETA grant receiving a benef it and if so are costs properly allocated based on the relative benef it received If costs are to be shared with other f unding streams are costs being allocated properly For example if your organization distributes commemorative coins that simply list the name of the organization or just the name of the program with no contact inf ormation and hands them to the board of directors a prudent person would view these as not advancing awareness of the program s services or employment f or participants. These would be considered memorabilia gif ts or souvenirs and would not be allowable under the Unif orm Guidance. On the other hand if your organization was trying to inf orm young parents about program services and attended a community event to promote their DOL-f unded grant program and provided a tote bag with the name of the grant program and contact inf ormation as a way f or individuals to f ind out about services f unded by the grant a prudent person would f ind that cost reasonable. The tote bag used as an outreach tool would benef it the program by recruiting potential participants using a very low-cost item that would be re-used and seen and thus help potential participants access those program services. These costs would be reasonably calculated to help increase enrollment as opposed to just commemorating an event or promoting an organization itself and not the grant program and its services. c. Ways to Conduct Outreach Once you understand the terms used in the Unif orm Guidance and understand how to determine allowability you can explore the many ways to conduct outreach. Below is a list of several examples of activities and platf orms allowed with grant f unds. In-Person Outreach Attending a local f air with materials about where to go to get help with f inding a job developing a resume obtaining career advice and learning interview skills is allowable. For each type of special or targeted population the grantee may need a unique method or strategy f or locating attracting and retaining participants f or your program. If the grantee does not have enough staf f consider conducting outreach through organizations that are willing and able to spread the grant s key messages to their audience. 6 Consider meeting potential participants at community locations such as libraries religious institutions laundromats grocery stores f airs industry events and other local events. Reach out to local businesses like barber shops and hair salons movie theaters sporting events and restaurants and ask them to post and share the organization s poster or sign to educate customers about the program or grant-f unded services. Consider which organizations are trusted by local communities and where inf ormation can create subsequent word-of-mouth inf ormation sharing. Local businesses may also allow grantees to join existing events they are planning or they may permit grantees to use their location as a venue f or outreach and enrollment events to promote the grant s opportunities. In addition to asking community partners and community leaders to spread the word that grantees are providing services also ensure that they have enough inf ormation about the services being provided and where individuals might f ind value so that they are able to ref er individuals to the organizations that can best help them. Other in-person activities you might undertake f or outreach include but are not limited to attendance at f acilitation of collaboration with or participation in job career f airs rapid response events one-stop satellite centers mobile one-stops high school college career days and other interviews etc. Consider setting up a recruitment display table so that inf ormation about grant related services provided by the organization may be distributed. It is appropriate to have advertising materials to promote the program such as a brochure pamphlets or f lash drives at a public relations event. Materials created to achieve grant objectives outcomes and f or the purpose of outreach at in-person events and to f acilitate engagement between staf f and the public are allowable. Materials used to educate the public about the award s activities services and program of f erings are allowable and encouraged. Print Printed outreach materials are by f ar the most popular f ormat f or outreach campaigns and are allowable costs. They can include a variety of items such as advertising and written articles in the local newspaper or neighborhood newsletter inf ormational postcards brochures and f lyers doorknob hangers pamphlets and leaf lets. Other examples may also include bus stop signage benches banners billboards vehicle wraps etc. QR codes may also be used in print media to direct potential participants to online inf ormation on the grant f unded activities services or programs. 29 CFR 38.40 b specifically authorizes use of notices about openings in the recipient s programs and or activities to schools and community service groups that serve various populations. 7 ETA broadly interprets printed outreach materials that promote the activities services and programs of the grant award to mean ef f orts to educate enroll employ and or extend ref errals to customers with interests in ETA s publicly f unded workf orce development ef f orts. Radio and TV Local radio and TV stations are a great way to advertise grant services and are usually cost ef f ective f or media coverage. Grant organizations should research and reach out to members of the media who may cover topics related to its grant award. There may be a specific radio or TV station reporter who covers a particular neighborhood or local community. For media engagement consider public service announcements PSAs and press releases. If there is no advertising budget sharing radio PSAs or coordinating on-air interviews with local radio stations is another way to build awareness of the services and supports provided by the grant. Websites The organization or program website is an excellent way to provide practical inf ormation about how to obtain services to participants and to community members that are seeking to engage with your organization. The organization will benef it f rom keeping the website current and easy to navigate especially if using QR codes that direct to the site to remind people of the activities services and programs of a specif ic event. Note that all websites f unded with f ederal f unds must meet the accessibility requirements established by section 508 of the Rehabilitation Act of 1973. See Section 4e of this TEGL f or more inf ormation about ensuring accessibility of online electronic and hard copy materials. Email Communication Email remains a usef ul way to disseminate inf ormation to participants and to potential partners in and outside the public workf orce system. Signature lines can include an additional website link QR code or description of an upcoming event or workf orce activities services and or program offerings. Use plain language wherever possible. Text Messaging SMS Applications Grantees can continue outreach to program participants with text messaging applications. These may be particularly well-suited to grantees who need to communicate with participants in real time e.g. those that pair participants with case managers . Additionally this modality is a way to remind participants of upcoming appointments or outstanding documents to promote a new program service of f ering or to blast out employment opportunities. Text messaging applications can also bolster traditional and ef f ective word-of- mouth outreach by prompting participants who may be in the company of other potential eligible candidates to speak about the opportunity to put it on their social media accounts or to f orward the text to others who may benef it. Another advantage of some texting tools are f unctions that can automate messages to go out at certain times to groups of people and even to track analytics such as if and when people open the messages or click on 8 links. Such data can be helpful f or programs to use to adapt their outreach. As with all activities grantees must ensure participant data privacy. Also it is important to review the data privacy policies of these text messaging applications and other social media platf orms. Social media The use of grant f unds to create social media accounts such as Instagram Facebook LinkedIn and other platf orm accounts to promote the grant services of f ered raise awareness of the program and strengthen relations with the community is an ef f ective way to virtually connect with customers regardless of distance. This is not an exhaustive list however grantees must comply with the grant award terms especially those f or prohibited platf orms vendors. For instance the grantee can f ollow other local community-based organizations on social media like their Facebook stories congratulate their progress on LinkedIn and share photos and short clips of them on its Instagram and do not f orget to tag them . These are all cost-ef fective ways to create a social media presence online. Please note there may be Federal or state laws that prohibit the use of certain platf orms so grantees should be aware of any restrictions before use. In addition grant award terms may prohibit certain activities such as lobbying. These restrictions apply to social media activity as well. For more ideas on how to develop social media strategies view the webinar Yes WIOA Can Post Like Follow Share Using Social Media as an Outreach and Marketing Tool. Quick Response Codes also known as QR Codes. QR codes are a square holding a barcode-like graphic comprised of machine-readable inf ormation. When someone uses a cell phone to take a picture of the QR code the phone recognizes the machine-readable information and can then go to a specif ic website. QR codes are a quick way to disseminate information and are used in every f acet of lif e f rom viewing a menu at a restaurant to shopping. These codes can provide inf ormation about a product or service which is then delivered quickly to a user s device. QR codes require minimal space are easy to scan can store a good amount of information and can be used to link to text digital business cards multimedia and social media channels. Influencers Inf luencers are people that have of ten amassed large f ollowings via dif f erent types of media platf orms and use their power of inf luence to communicate inf ormation. Inf luencers may be able to assist grantees in conducting outreach activities by communicating to potential participants what programs and services they of f er. Grantees using a contracted personality should provide details speaker s notes to the inf luencer to promote the Federal award s activities services and programs. When considering whether to use an inf luencer f or outreach one should consider the Unif orm Guidance s Cost Principles. Other things that might be considered are the inf luencer s reputation f ollower base any state or local vetting requirements the receptivity of potential participants the 9 technology access of participants and the cost benef it compared to a more traditional outreach modality. Inf luencer use is an outreach strategy that may be a powerf ul recruitment tool when assessed and used properly. Blog and Podcast Interviews These platf orms are usually interactive content that may be individually or serially posted and can discuss a Federally-f unded activity service or program of f ering to a specif ically targeted audience. They are typically short in length and access to some podcasts may require a subscription service. The f requency of use potential participant cost and availability of ongoing content should all be considered when undertaking this outreach modality. Mobile American Job Centers AJCs or workforce service delivery vehicles To reach people where they live shop and gather particularly in more rural areas grantees may consider purchasing a vehicle to conduct outreach as well as provide employment and training services. The Uniform Guidance considers motor vehicles as general-purpose equipment which are allowable under the Cost Principles. Costs to repair and maintain the vehicle are also allowable. The costs of the vehicle and its maintenance must meet all the f actors of allowability outlined in 2 CFR 200.403 and in some circumstances prior written approval f rom DOL-ETA may be required. If the motor vehicle benefits two or more programs the cost of the mobile AJC and the costs to maintain the vehicle must be allocated to the other programs based on the relative benef it received 2 CFR 200.405 d . ETA encourages grantees to leverage relationships with other partners that serve the same community or partners and that may have the same purpose or mission when purchasing staf f ing and maintaining a mobile AJC unit. d. Outreach in Multiple Languages Grantees can use f unds to create materials in multiple languages or to procure translation and interpretation services. It is important when developing outreach strategies to make sure all potential participants including those that speak languages other than English are aware of services available. Access to vital inf ormation which may include certain outreach materials in a language the participant can understand is key to promote and ensure equity. Of f ering materials translated into the languages used in the community is a key ef f ort to improve outreach and indeed may be required depending on the circumstances. See 29 C.F.R. 38.9. Additionally as a method to make inf ormation accessible to people that speak languages not f requently used in the community consider expanding outreach ef f orts to individuals who have Limited English Prof iciency LEP through the use of a language access guide called the I Speak Card . The I Speak Card is a language identif ication card poster that will assist in identif ying a pref erred language f or potential participants that speak a language other than English so they can obtain the necessary assistance. Organizations can use such a card to pinpoint the appropriate speakers f or anyone that requests services through your 10 organization. Also visit the LEP website https www.lep.gov f or tips on addressing language barriers. Lastly consider partnering with local communities that serve a diverse population f or assistance in draf ting culturally competent outreach materials in a variety of languages as this will help build a stronger relationship and presence with the local community. e. Accessibility Grantees must make inf ormation about their services accessible to individuals with disabilities by providing auxiliary aids and services including inf ormation in alternative f ormats and can use f unds to ensure outreach materials including f or example printed materials f orms and presentations are accessible. In addition when developing procuring maintaining or using electronic and inf ormation technology with Federal f unds including websites and electronically stored documents or inf ormation grantees should provide access to and use of inf ormation and data f or individuals with disabilities that is comparable to what is provided f or individuals without disabilities. Grantees can ref er to Government Services Administration s GSA website on electronic and inf ormation technology accessibility www.Section508.gov as a resource. GSA is the government s technical advisor f or digital accessibility and provides guidance and training in numerous areas. Document creation sof tware like Microsof t Word has tools and accessible design templates that can help to create accessible content f rom the start. Moreover when designing websites accounting f or accessibility at the outset is much easier than readjusting the site later to make it accessible f or customers. Also please note that specif ic accessibility standards apply to QR codes. DOL s Of f ice of Disability Employment Policy DOL s Civil Rights Center and ETA have created a WIOA 188 guide to nondiscrimination f or individuals with disabilities available at https www.dol.gov agencies oasam centers-of f ices civil-rights- center statutes section-188-workf orce-innovation-opportunity-act guide. The guide provides several examples of making materials spaces and services more f ully accessible f or individuals with disabilities. As noted above this guidance provides multiple examples but does not address every potential scenario. ETA encourages grantees to review their outreach plans and consider the examples provided in order to most ef f ectively reach and best serve jobseekers and employers. 5. Inquiries. Please direct inquiries to the appropriate Regional Of f ice. 6. References. Workf orce Innovation and Opportunity Act WIOA Pub. L. 113-128 29 U.S.C. 3101 et seq. The Nondiscrimination and Equal Opportunity Provisions Section 188 of WIOA https www.ecf r.gov current title-29 subtitle-A part-38 Rehabilitation Act of 1973 Pub. L. 93-112 29 U.S.C. 701 et seq. Unif orm Guidance 2 CFR Part 200 and DOL s exceptions 2 CFR Part 2900 11 TEGL No. 16-16 One-Stop Operations Guidance for the American Job Center Network https www.dol.gov agencies eta advisories training-and-employment- guidance-letter-no-16-16 TEGL No. 17-16 Infrastructure Funding of the One-Stop Delivery System https www.dol.gov agencies eta advisories training-and-employment-guidance- letter-no-17-16 Training and Employment Notice No. 24-18 Updated Promising Practices in Achieving Nondiscrimination and Equal Opportunity A Section 188 Disability Reference Guide https www.dol.gov agencies eta advisories training-and- employment-notice-no-24-18 ETA webinar titled Yes WIOA Can Post Like Follow Share Using Social Media as an Outreach and Marketing Tool held January 11 2023. Available at https www.workf orcegps.org events 2023 01 11 19 49 Outreach-and-Marketing- f or-the-Public-Workf orce-Development-System-2 ETA webinar titled Outreach and Marketing for the Public Workforce Development System Exploring the Possibilities held on October 11 2022. Available at https www.workf orcegps.org events 2022 10 11 18 35 Outreach-and-Marketing- f or-the-Public-Workf orce-Development-System-Exploring-the-Possibilities 7. Attachment. Attachment I. Legislative Regulatory and Unif orm Guidance Language Related to Outreach I-1 Attachment I Statutory and Regulatory Uniform Guidance Language Related to Outreach This attachment provides citations f rom relevant statutes and regulations including the Unif orm Guidance. The Unif orm Guidance is a set of regulations issued by the Of f ice of Management and Budget that apply to all grants in the Federal government. Accessibility from Rehabilitation Act of 1973 sec. 508 All materials produced with f ederal f unds must be accessible to individuals with disabilities sometimes ref erred to as being 508-compliant in a ref erence to the statutory requirements of the Rehabilitation Act of 1973 sec. 508. The f ull text of the statute is available at https www.access-board.gov law ra.html. The Access Board is an independent f ederal agency that promotes equality f or people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards. Created in 1973 to ensure access to f ederally f unded f acilities the Access Board is now a leading source of inf ormation on accessible design. The Access Board develops and maintains design criteria f or among other things inf ormation and communication technology. It also provides technical assistance and training on these requirements and on accessible design. The Americans with Disabilities Act ADA and the WIOA sec. 188 non-discrimination requirements also require that services and inf ormation about services to be accessible to individuals with disabilities. The ADA is available at https www.access- board.gov law ada.html and the WIOA sec. 188 nondiscrimination provisions can be f ound at https www.dol.gov agencies oasam centers-of f ices civil-rights-center statutes section-188- workf orce-innovation-opportunity-act. WIOA s implementing regulations also address accessibility requirements and protections f or individuals with disabilities. See 29 C.F.R. 38.5 38.12-17. Acknowledging Federal Funding in Public Communications Stevens Amendment Advertising and public relations outreach activities must adhere to grant terms and conditions including the Stevens Amendment a provision included since 1989 in DOL s annual appropriation. This provision requires DOL recipients to acknowledge f ederal f unding contributions when making public any projects or programs that DOL f unded through its annual appropriation. Recipients should maintain support documentation f or advertising and public relations outreach activities in accordance with record retention requirements where applicable. Grantees are reminded to f ollow the terms of their grant agreement as not all programs have the Stevens Amendment requirement e.g. H-1B Skills Grants f unding . I-2 The Stevens Amendment requires When issuing statements press releases requests f or proposals bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money all recipients receiving Federal f unds included in WIOA shall clearly state 1 the percentage of the total costs of the program or project which will be f inanced with Federal money 2 the dollar amount of Federal f unds f or the project or program and 3 percentage and dollar amount of the total costs of the project or program that will be f inanced by non-governmental sources. Advertising and Public Relations Costs from 2 CFR 200.421 the Uniform Guidance a The term advertising costs means the costs of advertising media and corollary administrative costs. Advertising media include magazines newspapers radio and television direct mail exhibits electronic or computer transmittals and the like. b The only allowable advertising costs are those which are solely f or 1 The recruitment of personnel required by the non-Federal entity f or performance of a Federal award See also 200.463 2 The procurement of goods and services f or the perf ormance of a Federal award 3 The disposal of scrap or surplus materials acquired in the perf ormance of a Federal award except when non-Federal entities are reimbursed f or disposal costs at a predetermined amount or 4 Program outreach and other specific purposes necessary to meet the requirements of the Federal award. c The term public relations includes community relations and means those activities dedicated to maintaining the image of the non-Federal entity or maintaining or promoting understanding and f avorable relations with the community or public at large or any segment of the public. d The only allowable public relations costs are 1 Costs specif ically required by the Federal award 2 Costs of communicating with the public and press pertaining to specif ic activities or accomplishments which result f rom perf ormance of the Federal award these costs are considered necessary as part of the outreach ef f ort f or the Federal award or 3 Costs of conducting general liaison with news media and government public relations of f icers to the extent that such activities are limited to communication and liaison necessary to keep the public inf ormed on matters of public concern such as notices of f unding opportunities f inancial matters etc. e Unallowable advertising and public relations costs include the f ollowing 1 All advertising and public relations costs other than as specif ied in paragraphs b and d of this section I-3 2 Costs of meetings conventions convocations or other events related to other activities of the entity see also 200.432 including i Costs of displays demonstrations and exhibits ii Costs of meeting rooms hospitality suites and other special f acilities used in conjunction with shows and other special events and iii Salaries and wages of employees engaged in setting up and displaying exhibits making demonstrations and providing brief ings 3 Costs of promotional items and memorabilia including models gif ts and souvenirs 4 Costs of advertising and public relations designed solely to promote the non-Federal entity. Affirmative Outreach from 29 CFR 38.40 Recipients must take appropriate steps to ensure that they are providing equal access to their WIOA Title I-f inancially assisted programs and activities. These steps should involve reasonable ef f orts to include members of the various groups protected by these regulations including but not limited to persons of dif f erent sexes various racial and ethnic national origin groups various religions individuals with limited English prof iciency individuals with disabilities and individuals in dif f erent age groups. Such ef f orts may include but are not limited to a Advertising the recipient s programs and or activities in media such as newspapers or radio programs that specif ically target various populations b Sending notices about openings in the recipient s programs and or activities to schools or community service groups that serve various populations and c Consulting with appropriate community service groups about ways in which the recipient may improve its outreach and service to various populations. Cost Principles from the Uniform Guidance at 2 CFR 200.403 The Cost Principles of the Unif orm Guidance describe general criteria all costs must meet in order to be allowable. Paraphrased below the f ull text can also be f ound at 2 CFR 200.403. Be necessary and reasonable f or the perf ormance of your DOL ETA award and be allocable to the award. Conf orm with Federal law guidelines and grant terms. Be consistent with policies and procedures. Costs must be incurred to support your DOL ETA award consistent with governing statutes regulations and your policies and procedures that apply unif ormly to both Federal and non-Federal awards. Receive consistent treatment. Costs must receive the same accounting treatment as costs that your organization incurred in similar circumstances. Must be in accordance with Generally Accepted Accounting Principles GAAP . Cannot be included as a cost or used to meet cost-sharing or matching requirements of any other Federal award except as specif ically provided by f ederal law or regulation. Be properly and adequately documented. I-4 Cost must be incurred during the approved budget period. The Federal awarding agency is authorized at its discretion to waive prior written approvals to carry f orward unobligated balances to subsequent budget periods pursuant to 200.308 e 3 . When testing f or reasonableness of a cost consider the prudent person test. In the prudent person test the recipient must consider Would a prudent person use Federal f unds to pay for the advertising or public relations activities Would the recipient have used its own f unds to conduct outreach efforts related to these activities Recipients must be able to demonstrate that advertising and public relations costs meet all the f actors of allowability before it can be charged to a DOL ETA award. Costs of Infrastructure from WIOA sec. 121 h 4 The term costs of inf rastructure used with respect to a one - stop center means the non - personnel costs that are necessary f or the general operation of the one -stop center including the rental costs of t he f acilities the costs of utilities and maintenance equipment including assessment -related products and assistive technology f or individuals with disabilities and technology to f acilitate access to the one -stop center including the center s planning and outreach activities. Language Access from Section 188 of WIOA 29 CFR 38.9 requires that A recipient must take reasonable steps to ensure meaningf ul access to each limited English prof icient LEP individual served or encountered so that LEP individuals are ef f ectively inf ormed about and or able to participate in the program or activity. 1 Reasonable steps generally may include but are not limited to an assessment of an LEP individual to determine language assistance needs providing o ral interpretation or written translation of both hard copy and electronic materials in the appropriate non -English languages to LEP individuals and outreach to LEP communities to improve service delivery in needed languages. A recipient must provide adequate notice to LEP individuals of the existence of interpretation and translation services and that these language assistance services are available f ree of charge. With regard to vital inf ormation 1 For languages spoken by a signif icant number o r portion of the population eligible to be served or likely to be encountered a recipient must translate vital inf ormation in written materials into these languages and make the translations readily available in hard copy upon request or electronically such as on a Web site. Written training materials of f ered or used within employment -related training programs as def ined under 38.4 t are excluded f rom these translation requirements. However recipients must take reasonable steps to ensure meaningf ul access as stated in 38.9 b . I-5 2 For languages not spoken by a signif icant number or portion of the population eligible to be served or likely to be encountered a recipient must take reasonable steps to meet the particularized language needs of LEP in dividuals who seek to learn about participate in and or access the aid benefit service or training that the recipient provides. Vital inf ormation may be conveyed orally if not translated. Noting Equal Opportunity in Public Communications from 29 CFR 38. 38 The WIOA nondiscrimination regulations at 29 CFR 38.38 require that grantee s indicate that the Federally -f unded program or activity in question is an equal opportunity program and that auxiliary aids and services are available upon request to individuals with disabilities in recruitment brochures and other materials that are ordinarily distributed or communicated in written and or oral f orm electronically and or on paper to staf f clients or the public at large.