Background. In 1984 Congress passed the Single Audit Act. Tribal governments are one of the groups to which it applies. OMB Circular A-128 was prepared to implement the Act. The attached regulations implement OMB Circular A-128 (for tribes) and OMB Circular A-110 (for non-profit organizations). The answers to the questions were provided by the staff of the Department of Labor's (DOL) Office of the Inspector General (IG), Division of ETA Audit Compliance. Grantees having more questions on audits are invited to submit them to DINAP. Answers will be published in a subsequent bulletin for the benefit of all grantees. Action. The attached documents should be carefully studied and the regulations followed. Inquiries. Contact your DINAP Federal Representative.

Reference. None. Information. On several occasions DINAP has been asked by Native American grantees if JTPA funds could be used as matching funds for other grants--Federal, State or other. There is nothing in JTPA or its regulations which authorizes or prohibits the use of JTPA funds as matching funds under any other Federal or State or other program. The acceptability of JTPA funds as matching funds for another grant must be decided by the agency which would award the funds. Of course, JTPA funds which are used as matching funds can only be expended in the "matched" programs for JTPA authorized activities. Inquiries. Contact your DINAP Federal Representative.

Reference. Debt Collection Act of 1982 (Public Law 97-365) and 29 CFR, Part 20. Background. The Debt Collection Act authorizes the Federal government to disclose to credit reporting agencies information concerning claims owed the United States by debtors. Accordingly, the attached final rule establishes the procedures the Department of Labor will follow in making disclosures of information on debtors to credit reporting agencies. The Department's debt collection regulations govern Employment and Training Administration debt collection. Action. Grantees should review the attached Debt Collection final rule and become familiar with the procedures contained therein. Effective Date. Immediately. Inquiries. Contact your DINAP Federal Representative.

Reference. Debt Collection Act of 1982 (P.L. 97-365) , 29 CFR, Part 20 DINAP Bulletin 85-22. Background. The background section in DINAP Bulletin 85-22 refers only to Subpart A of the final rules of the Debt Collection Act of 1982. Subpart B - Administrative Offset and Subpart C - Interest, Penalties and Administrative Costs should have been included. Subparts B and C as well as Subpart A govern the Employment and Training Administration's debt collection activities. Action. Grantees should review and become familiar with all three subparts of the final rules. Effective Date. Immediately. Inquiries. Contact your DINAP Federal Representative.

References. JTPA regulations at 20 CFR 632.39, 632.174, and 632-263. Background. This bulletin applies to Job Training Partnership Act (JTPA) Title IV-A and Title II-B funds provided directly to grantees. a. General. The JTPA regulations at 20 CFR 632.39 state: "All administrative funds for all programs operated under separate sections of the Act...may be accounted for separately...or may be pooled into one fund." b. Title IV-A Funds. The JTPA regulations at 20 CFR 632.174 state: "Administrative costs for this sub-part...shall not exceed 20 percent of the funds available." c. Title 11-B Funds. The JTPA regulations at 20 CFR 632.263 state: 'Administrative costs for this sub-part...shall not exceed 20 percent of the funds available.' d. Funds Available. The term "funds available' is defined as new-obligational authority plus authorized carryover. e. Explanation. Grantees who operate both a Title IV-A program and a Title 11-B program have the option of either allocating administrative costs back to these programs according to generally accepted accounting principles and OMB circular A-87 or establishing an ACP. If a grantee chooses to allocate the costs back tp the program, a cost allocation plan distributing the administrative costs shall be developed. Since these administrative costs are direct costs, there is no requirement for prior Federal approval of this cost allocation plan. It shall be developed and maintained on file for Federal review. If a grantee chooses to pool its administrative funds, administrative expenditures will need to be allocated to the program only for quarterly reporting puposes. Any formula distributing these costs will be acceptable as long as 1) no program contributes more to the pool than the regulations allow, 2) no more is distributed back to a program than that program contributed, and 3) only allowable JTPA administrative costs are charged to the pool. In both options the administrative limit of 20 percent must be complied with. The pooled administrative funds from each program lose their identity and grantees, auditors and Federal Representatives should monitor only the allowability of the costs incurred and the amounts contributed by the title IV-A and Title II-B program. The ACP contributions may be increased or decreased during the year as long as they o not exceed the 20 percent limit. ACP Instructions. a. Planning (Budget Information Summary). Grantees who choose to use the ACP should enter "ACP" beside the term "Administration" on Line 4 of both the TItle IV-A and Title II-B Budget Information Summary (BIS). The amount shown in the 4th column of Line 4 of each BIS will be the total planned contribution from each title to the ACF and will be no more than 20 percent of the total funds available for each title. Grantees should not submit a seperate BIS for the ACP. Grantees who change the contribution to the ACP should submit a revised BIS with the next quarterly report. b. Reporting. When preparing quarterly reports grantees may use any formula to determine how much of the total administrative costs should be charged to their Title IV-A program and to their Title II-B program, as long as no more is allocated back to the program than was originally contributed. Grantees should not submit a seperate report for the ACF. c. Authorized Carryover. After determining how much of the total administrative costs will be reported for the Title IV-A and Title II-B program, grantees can determine the carryover for each program by subtracting the reported costs from the contribution. The ACP carryover for each program should be added to the program and the next year's new obligational authority for each program. The result is the total available funds for the next year from which a contribution, up to twenty percent, to next year's ACP may be made. Grantees are reminded that policy on authorized carryover is issued annually. Action. Grantees who choose to use an ACP should follow the instructions above. Questions. Contact your DINAP Federal Representative.

References. DINAP Bulletin No. 85-16. Information. Attached is a listing of the contact points for audit information. Tribal grantees in virtually every case will have the Department of the Interior as their cognizant agency and should contact it for audit information. A17 other grantees should contact the U.S. Department of Labor Regional Office having jurisdiction over their area, as indicated is the attached. Inquiries. Consult your DINAP Federal Representative.