TEGL 08-23 PDF.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION SCSEP CO RRESPONDENCE SYMBOL OWI-DNPTTA DATE January 24 2024RESCISSIONS None EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 08-23TO SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM SCSEP GRANTEES STATE AND TERRITORIAL GOVERNORS STATE WORKFORCE LIAISONS STATE AND LOCAL WORKFORCE BOARD EXECUTIVES FROM BRENT PARTON Principal Deputy Assistant Secretary SUBJECT Information Technology IT Implementation and Support Funding for Senior Community Service Employment Program SCSEP State and Territorial Grantees for Program Year PY 2023 1. Purpose . To announce the availability of 9.5 million to assist SCSEP state and territory grantees with IT implementation and support costs related to the Department of Labor transition and implementation of the new Grantee Performance Management System GPMS case management tool. These grants will be funded through SCSEP recaptured funds. 2.Action Requested. To apply for PY 2023 IT Implementation and Support Grant funds SCSEP grantees must follow the instructions in this TEGL and submit all documents by March 26 2024. 3.Summary and Background. a.Summary The Employment and Training Administration ETA went live with GPMS July 1 2022 creating a new case management tool to modernize service delivery and data validation for the SCSEP program. ETA anticipates however that SCSEP State and Territorial Grantees may still face additional administrative and program costs to implement this system going forward. To help State and Territorial Grantees cover these implementation and support costs ETA awarded an initial round of limited funding in June 2023 and is now making available one additional round of funding authorized under Section 517 c of the Older Americans Act OAA 42 U.S.C. 3056o c and the Further Consolidated Appropriations Act 2020 P.L. 116-94 . The grant period of performance will be 12 months with an anticipated start date of July 1 2024-June 30 2025 however ETA encourages grantees to spend these funds earlier in the period of performance since such investments may expedite the success of a grantee s transition to GPMS. ETA will award all IT Implementation and Support Grants by June 30 2024. 2 b.Background Section 517 c of the Older Americans Act OAA provides that the Secretary of Labor may recapture any unexpended funds for the program year and re- obligate such funds within the 2 succeeding program years for 1 incentive grants to entities that are State grantees or national grantees under section 502 b 2 technical assistance or 3 grants or contracts for any other activity under this title. Additionally the Further Consolidated Appropriations Act 2020 P.L. 116-94 provides that SCSEP funds appropriated in that year may be recaptured and reobligated in accordance with section 517 c of the OAA. In accordance with OAA section 517 c 3 ETA is making a portion of the PY 2020 recaptured funds available for obligation during PY 2023 exclusively for State and Territorial Grants and not National Grants that will cover the IT-related costs explained in this TEGL. 4.SCSEP Information Technology Implementation and Support Funding Opportunity. a.Eligibility Eligible applicants for this grant opportunity are current PY 2023 SCSEP State and Territorial Grantees and not National Grantees . b.Grant Activities SCSEP State and Territorial Grant recipients exclusively may use this funding for 1 additional personnel 2 technology-related supplies 3 technology-related equipment 4 contractual costs related to IT and data support and or 5 other costs which must be allowable under SCSEP regulations and 2 CFR 200 related to transitioning to and implementing the new GPMS case management system. c.Availability of Funds and Application Review and Award The Department expects to have available approximately 9.5 million of recaptured federal SCSEP funding. The Department intends to re-obligate this funding exclusively amongst SCSEP State and Territorial Grantees excluding National SCSEP Grantees pending their interest and submission of applications meeting the requirements of this TEGL. Only SCSEP State and Territorial Grantees are eligible and ETA encourages these grantees to apply and to ask for the maximum amount necessary to fully implement the model. SCSEP State and Territorial Grantees must submit a justification for the funding request based upon their need for the funds. However when determining this need eligible SCSEP State and Territorial applicants must consider the size and scope of the previous SCSEP base award. As a baseline point of reference we consider a request of 1 2 percent of the PY 2023 federal grant award with proper justification as likely appropriate for most if not all recipients. However we recognize new systems create certain fixed costs so for smaller SCSEP awards we will award no less than 150 000 regardless of how much the amount exceeds the general target of 1 2 percent. Final award amounts are subject to the availability of funds. If the cumulative funding requested by all applicants exceeds the amount of funds available all grant awards will be reduced proportionately. Conversely if the cumulative requests are lower than the 3 total available amount or if additional funds become available grant awards may be increased proportionately. If ETA does not receive responsive applications it may request applicants whose applications were deemed non-responsive to resubmit a revised application for reconsideration depending on the availability of funding. The Department may negotiate funding levels and program elements. Selected awardees will receive special conditions of award requiring the revision of the SF-424 and budget documents should there be discrepancies between funding requests and actual award amounts. To receive this implementation funding SCSEP State and Territorial applicants must meet all requirements described in this TEGL and submit a responsive application that addresses the grant application components outlined in this document as well as in Attachments I and II. If an applicant omits any of the documents or substantially fails to address the requirements of one or more of such documents ETA will deem their application nonresponsive and ineligible for funding consideration. ETA encourages applicants to submit quality final applications before the deadline. If an applicant submits multiple versions of an application ETA will consider the latest submitted application to be the official submission. d.Grant Application Requirements To achieve greater efficiency and as part of ETA s ongoing effort to streamline the grant award process grantees must submit the following items through Grants.gov 1 An electronically signed copy of an SF-424 - Application for Federal Assistance OMB Control No. 4040-0004 . 2 An SF-424A - Budget Information Form Non-Construction Programs OMB Control No. 4040-0006 . 3 A Budget Narrative that fully explains the projected costs reflected in each line item of the SF-424A see Attachment I for instructions . 4 A Project Narrative see Attachment 2 for instructions . e.Grants.gov Submission Process Applicants must submit the application package through Grants.gov. Applicants who need to register with Grants.gov may do so at the following hyperlink https www.grants.gov web grants applicants organization- registration.html. Registration is a one-time process applicants with a Grants.gov account do not need to register again. To submit the required application package applicants must 1 Select the Search Grants tab on the Grants.gov homepage. 2 Under the section Basic Search Criteria enter the Funding Opportunity Number ETA-TBD. 3 Select the link to the applicable Opportunity Number provided in the search results. 4 Select the Package tab. 5 Under the Actions column select Apply. An electronically submitted SF-424 through Grants.gov constitutes the official signed document and must reflect the total amount requested in item 18 Estimated Funding. 4 Item 11 must include the Catalog of Federal Domestic Assistance Number 17.235. ETA encourages application submission as soon as possible however applicat ions must be received by 11 59 PM EST on March 26 2024. This submission process may at times be complicated and time-consuming. As such the Department strongly encourages applicants to initiate the process as soon as possible to allow time to resolve unanticipated technical problems. Applicants must supply a Unique Entity Identifier UEI on the SF-424. If your entity is registered with the System for Award Management SAM SAM.gov your UEI has already been assigned and is viewable under your entity record. Organizations not registered with SAM.gov can obtain more information about a UEI at www.sam.gov. Before submitting applicants must also ensure their registration with SAM.gov. Applicants may find instructions for registering with SAM at https www.sam.gov. An awardee must always maintain an active SAM registration with current information during which it has an active Federal award or an application under consideration. To remain registered in the SAM database after the initial registration entities must review and update the registration at least every 12 months from the date of initial registration. Failure to register with SAM and maintain an active account will result in Grants.gov rejecting the application submission. For technical issues encountered during application submission applicants may call 800- 518-4726 or 606-545-5035 to speak to a Customer Support Representative or email grants.gov support The Contact Center is open 24 hours a day seven days a week but closes on federal holidays.f.Administrative and Program Costs Subpart H of the SCSEP regulations define the functions and activities that constitute administrative and program costs at 20 CFo 641.856 and at 20 CFR 641.864 respectively. Administrative costs include both personnel and non-personnel costs and both direct and indirect costs. AlsoI note that section 641.859 provides special rules governing the classification of SCSEP administrative and program costs. Given that this additional funding is separate from the SCSEP base funds proposed expenditures for this grant operate on a PY basis from July 1 through the following June 30 and are not required to meet the 13.5 percent administrative cost limits as required by formula provided in Section 506 of the Older Americans Act of 1965 OAA as amended 42 USC 3056d. g.Other Award Considerations At its discretion ETA intends to fund applicants who adequately demonstrate eligibility and meet the application requirements set out in this TEGL. 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 an electronic signature which constitutes a binding offer by the applicant. 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. 5 Depending on the severity of the findings the Grant Officer may elect to not provide the applicant a grant award or to impose conditions on the award. All applications deemed to be complete and responsive by the Grant Officer will go through a risk review process. Before making an award ETA will review information available through any OMB-designated repository of government-wide eligibility qualification or federal integrity information such as the Federal Awardee Performance and Integrity Information System FAPIIS and Do Not Pay. Additionally ETA will comply with the requirements of 2 CFR Part 180 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 technical 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 evaluated include Financial stability. Quality of management systems and ability to meet the management standards prescribed in the Uniform Grant Guidance. 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 available the extent to which any previously awarded amounts will be expended prior to future awards. Reports and findings from audits performed under Sub-part F Audit Requirements of the Uniform Grant Guidance 2 CFR 200.500 2 CFR 200.520 or the reports and findings of any other available audits and monitoring reports containing finds issues of non-compliance or questioned costs and The applicant s ability to effectively implement statutory regulatory or other requirements imposed on recipients. The selection of an organization as a recipient does not constitute approval of the grant application as submitted. Before the actual grant is awarded the Department may negotiate with an applicant regarding such items as program components staffing and funding levels and administrative systems in place to support grant implementation. If the negotiations do not result in a mutually acceptable submission the Grant Officer reserves the right to terminate the negotiations and decline to fund the application. The Department reserves the right to not fund any application related to this TEGL. h.Grantee Performance Reporting Requirements 1 Financial Reports. All ETA award recipients are required to report financial data on the ETA-9130 Financial Report. ETA-9130 reports are due no later than 45 calendar days after the end of each specified reporting quarter. Reporting quarter 6 end dates are March 31 June 30 September 30 and December 31. A final 9130 for the last quarter of the period of performance must be submitted no later than 120 calendar days after the quarter ends. See 2 CFR 200.344. Note On April 3 2023 ETA replaced 6 its legacy E-Grants Grantee Reporting System GRS by transitioning to the Payment Management System PMS for grant recipient submission of the quarterly ETA-9130 financial reports. PMS is operated by the U.S. Department of Health and Human Services HHS . Please see Training and Employment Notice No. 16-22 for additional information. 2 Performance Reports. Since these funds are specifically for IT implementation and support ETA is not asking for separate additional performance reports on employment outcomes of participants. However grantees that receive these funds should provide status updates on activities that the funds support in their quarterly narrative reports both how these funds are used and the status of any larger activity to which the funds are contributing. Grantees should continue to submit program performance reports for their base grants. i.Paperwork Reduction Act PRA Statement - 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 the Office of Management and Budget OMB under the PRA approves it and it displays a currently valid OMB Control Number 44 U.S.C. 3507 . SCSEP Performance Data Collection Approval OMB No. 1205-0040 expiration date November 30 2024 . Also notwithstanding any other provision 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 . According to the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless such collection displays a valid OMB control number. Public reporting burden for this collection of information is estimated to average 20 hours per response including time for reviewing instructions searching existing data sources gathering and maintaining the data needed and completing and reviewing the collection of information. Send comments about the burden estimated or any other aspect of this collection of information including suggestions for reducing this burden to the U.S. Department of Labor to the attention of the Departmental Clearance Officer 200 Constitution Avenue NW Room N-1301 Washington D.C. 20210. Comments may also be emailed to DOL PRA PUBLIC dol.gov. Please do not return your grant application to this address. Send only comments about the burden caused by the collection of information to this address. Send your grant application to the sponsoring agency as specified earlier in this announcement. The information being collected through this Training and Employment Guidance Letter is for the purpose of awarding a grant. This information is required to be considered for this grant. j.Notice of Grant Award ETA will issue a notice of grant award with new grant numbers and obligation amounts. 7 5.Inquiries. Questions regarding this guidance should be directed to Grant Specialist Flowers.Jeannette dol.gov. 6. References. Older Americans Act 42 USC 3056 et seq. as amended through Public Law 116-131 March 25 2020 Further Consolidated Appropriations Act 2020 P.L. 116-94 September 30 2020 Coronavirus Aid Relief and Economic Security Act of 2020 CARES Act Pub. L. 116-136 March 27 2020 Workforce Innovation and Opportunity Act WIOA Pub. L. 113-128 Sec. 121 Funding of One-Stop Infrastructure Paperwork Reduction Act of 1995 Pub. L. 104-13 May 22 1995 OMB Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal Awards published at 2 CFR Part 200 TEGL 17-20 Senior Community Services Employment Program -Updated Guidance on Priority of Service Durational Limits and State Plan Submissions April 15 2021 TEGL 17-16 Infrastructure Funding of the One-Stop Delivery System January 18 2017 and SCSEP Performance Data Collection OMB No. 1205-0040 expiration date November 30 2024 . 7.Attachment s . Attachment I Budget Narrative Instructions Attachment II Program Narrative Instruction -1 Attachment I Program Year PY 202 3 Information Technology IT Implementation and Support Funding for Senior Community Service Employment Program SCSEP Budget Narrative Instructions Applicants must provide a detailed Budget Narrative that fully explains the costs identified on each line item of the SF -424A Budget nformation Form. See the required information and related guidance below. a. Personnel List all staff positions working on the proposed grant project by title both current and proposed including the roles and responsibilities. For each position give the annual salary the percentage of time devoted to the project and the amoun t of each position s salary funded by the grant. This line item does include personnel hired by the sub -grantee to provide data entry migration and management of the case management tool. b. Fringe Benefits Provide a breakdown of the amounts and percentages that comprise fringe benefit costs such as health insurance F CA retirement etc. c. Travel For grant staff only specify the purpose number of staff traveling mileage per diem estimated number of in -state and out -of-state trips and other costs for each type of travel. d. Equipment dentify each item of equipment you expect to purchase that has an estimated acquisition cost of 5 000 or more per unit or if your capitalization level is less than 5 000 use your capitalization level and a useful lifetime of more than one year see 2 CFR 200.1 for the definition of Equipment . List the item quantity and the unit cost per item. tems with a unit cost of less than 5 000 are supplies not equipment. Additionally please note the following a. nformation technology systems are defined as computing devices ancillary equipment software firmware and similar procedures services including support services and related resources. 2 CFR 200.1 b. Computing devices are defined as machines used to acquire store analyze process and publish data and other information electronically including accessories or peripherals for printing transmitting and receiving or storing electronic information . 2 CFR 200.1 -2 c. While the definition of information technology systems includes computing devices such devices with a per -unit acquisition cost of less than the capitalization level established by the non -Federal entity for financial statement purposes or 5 000 are cla ssified as supplies not equipment. d. Procurement requirements for grant recipients are contained in the Uniform Administrative Requirements Cost Principles and Audit Requirements for Federal -1 Awards Uniform Guidance at 2 CFR 200.317 - .326. ETA does not approve or disapprove the procur ement method used by the recipient provided it is consistent with the requirements in the Uniform Guidance 2 CFR 200.317 - .326 . By their signature on the Grant Agreement the recipient has accepted these conditions and assured their compliance with a ppropriate procurement requirements. e. All equipment purchases require prior approval by a Grant Officer. Applicants should provide accurate estimates for proposed equipment expenditures in the application for this grant however the initial award of the T mplementation and Support Grants do es not constitute prior approval of the identified equipment costs. Selected awardees for these grants must submit a subsequent modification seeking prior approval which must include additional documentation for the Grant Officer to determine allowabi lity of the proposed costs. 2 CFR 2900.16 requires this request to be submitted not less than 30 days before the requested action is to occur. Selected awardees must consult their Federal Project Officer regarding the information required for the equipme nt modification request. e. Supplies dentify in the detailed budget the projected cost of supplies per category e.g. general office supplies desks chairs laptops printers other specialty items . Except for general office supplies list the item quantity and the unit cost pe r item. Supplies include all tangible personal property other than equipment. See 2 CFR 200.1 for the definition of Supplies. f. Contractual Under the Contractual line item delineate contracts and subawards separately. Contracts are defined according to 2 CFR 200.1 as a legal instrument by which a non -federal entity purchases property or services needed to carry out the project or program under a federal award. A subaward also defined under 2 CFR 200.1 means an award provided by a pass -through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass -through entity. t does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. For each proposed contract and subaward specify the purpose and activities to be provided and the estimated cost. -3 g. Construction Construction costs are not allowed and this line must be left as zero. Minor alterations to adjust an existing space for grant activities such as altering a space to accommodate T equipment may be allowable. We do not consider this as con struction and you must show the costs on other appropriate lines such as Contractual. h. Other Provide clear and specific detail including costs for each item so that the Grant Officer may determine whether the costs are necessary reasonable and allocable. List items such as stipends or incentives not covered elsewhere. i. ndirect Costs f you include an amount for indirect costs through a Negotiated ndirect Cost Rate Agreement or De Minimis on the SF -424A budget form then include one of the following -2 a. f you have a Negotiated ndirect Cost Rate Agreement N CRA provide an explanation of how the indirect costs are calculated. This explanation should include which portion of each line item along with the associated costs are included in your cost allo cation base. Also provide a current version of the N CRA. or b. f you intend to claim indirect costs using the 10 percent de minimis rate please confirm that your organization meets the requirements as described in 2 CFR 200.414 f . Clearly state that your organization does not have a current negotiated including pr ovisional rate and is not one described in 2 CFR 200 Appendix V D 1 b . Applicants choosing to claim indirect costs using the de minimis rate must use Modified Total Direct Costs see 2 CFR 200.1 below for definition as their cost allocation base. Provide an explanation of which portion of each line item along with the associated costs are included in your cost allocation base. Note that there are various items not include d in the calculation of Modified Total Direct Costs. See the definitions below to assist you in your calculation. Modified Total Direct Cost MTDC 2 CFR 200.1 means all direct salaries and wages applicable fringe benefits materials and supplies services travel and subawards and subcontracts up to the first 25 000 of each subaward or subcontract regardless of the period of performance of the subawards and subcontracts under the award . MTDC excludes equipment capital expenditures charges for patient care rental costs tuition remission scholarships and fellowships participant support costs and the portion of each subaward and subcontract more than 25 000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs and with the -4 approval of the cognizant agency for indirect costs. Participant support costs are defined below. Participant Support Costs 2 CFR 200.1 mean direct costs for items such as stipends or subsistence allowances travel allowances and registration fees paid to or on behalf of participants or trainees but not employees in connection with conferences or training projects. The following link contains information regarding the negotiation of ndirect Cost Rates at DOL indirect cost rates. Note that the SF -424 SF -424A and Budget Narrative must include the entire federal grant amount requested. Do not show leveraged resources on the SF -424 and SF -424A. You should describe leveraged resources in the Budget Narrative. Applicants should list t he same requested federal grant amount on the SF -424 SF -424A and Budget Narrative. f minor inconsistencies are found between the budget amounts specified on the SF -424 SF -424A and the Budget Narrative DOL will consider the SF -424 the official funding amount requested. II-1 Attachment II Program Year PY 202 3 Information Technology IT Implementation and Support Funding for Senior Community Service Employment Program SCSEP Program Narrative Instructions All grantees must provide a program narrative that concisely covers the areas below. Justify the request for IT implementation and support funds by providing evidence of the following. Ensure that these descriptions are consistent with the information in y our Budget Narrative. Include a. A detailed description of the activities planned on how the funds will be spent directly on the Grantee Performance Management System GPMS transition functions. b. A description of how the funds will improve the effectiveness of the transition to GPMS related to hiring training data migration data validation hardware or software technologies and equipment to implement the new system most effectively. c. Information related to the temporary hiring or contracting of personnel needed to facilitate the data migration data connectivity and or other tasks related to GPMS implementation. d. Justification for the purchase of supplies such as computers or other hardware to upgrade outdated equipment incompatible with the new case management tool and proportionate to the size of the grantee program. e. Justification for the purchase of any equipment or ancillary supplies needed by the grantee to fully implement the GPMS case management tool and in accordance with the statutes and laws governing SCSEP grants. f. A schedule to monitor and audit grant funds along with assurances funding will be spent only on administrative and program costs related to GPMS transition and implementation. g. A financial status report is required at the time all funds have been expended or the grant period has expired. On the financial status report grantees must include any qualitative outcomes not directly supported by final expenditures.