H1B Technical Skills Training Grant Program Administrative Requirements July 2003

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H-1B Technical Skills Training Grant Program
Administrative RequirementsJuly 2003

• Isabel Danley
• Division of Financial and Grants Management
  Policy and Review
• U.S. Department of Labor
• Employment and Training Administration

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Todays Topics

• Uniform Administrative Requirements
• Allowable Costs
• Start Up Costs
• Administrative Costs
• Matching Requirement

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Governmental Entities

• State, Local, Indian Tribal Govt
• OMB Circular A-102
• 29 CFR, Part 97

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Non-Government Entities

• Non-Profit, Institutions of Higher Education
  Commercial Organizations
• OMB Circular A-110
• 29 CFR, Part 95

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Cost Principles

• OMB Circular A-87
• OMB Circular A-122
• OMB Circular A-21
• 48 CFR, Part 31
• 45 CFR, Part 74, Appendix E

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General Rules

• Reasonable Necessary
• Allocable
• Authorized or Not Prohibited
• Consistent Treatment
• Not Used as Match
• Adequately Documented
• Consistent with GAAP

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Selected Items

• 3 Types of Costs
• Allowable
• Unallowable
• Allowable with Conditions
• Program Specific Costs

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Funds for Start Up

• Partnerships - Primarily Small Businesses
• 10 of Grant Award Amount
• Maximum of 150,000
• All other Partnerships
• 5 of Grant Award Amount
• Maximum of 75,000

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Start Up Costs

• Costs to start the partnerships
• Costs to start new training programs/projects
• For period of no more than two months

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Administrative Costs

• 10 Limitation
• WIA definition
• 20 CFR 667.220
• Function/Activity Based

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H1B REPORTING

• STANDARD FORM 269
• ON-LINE ELECTRONIC REPORTING
• ACCRUAL BASED REPORTING
• (CASH OUTLAYS, PLUS ADDITIONAL ACCRUALS)

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Reporting of Start Up andAdministrative Costs

• Remarks Section of SF269

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H1B Match Requirement

• 75 fund stream - Local WIBs
• 50 Match Cash or In-Kind
• 25 fund stream partnerships
• 100 Match Cash or In-Kind

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H1B MATCH REQUIREMENT

• OF 100 MATCH
• - AT LEAST 50 MUST COME FROM BUSINESS
  PARTNERS

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Matching Requirements

• 29 CFR 97.24
• State, local and Indian Tribal governments
• 29 CFR 95.23
• Non-Profits, Hospitals, Institutions of Higher
  Education, and Commercial Organizations

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What is Match?

• Additional non-Federal funds used to support
  grant activities.
• The funds are made available to the program
  through cash expenditures or cash and in-kind
  contributions.

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Matching Requirements

• Spent on allowable activities
• In accordance with cost principles
• No administrative cost limitation

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Match Exclusions

• Costs of construction/purchase of facilities
• Unallowable WIA H1B cost
• Costs of equipment acquisition
• Depreciation or use allowance is permitted
• Costs paid by program income

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More Exclusions

• Difference between earnings and costs
• Profit or program income
• Costs paid by Federal funds
• Costs used as a match for other Programs

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Employer Share of Participant Wages

• Ordinarily Unallowable
• For Meeting H1B Match ONLY
• Trainees are bona-fide Employees
• Not replacements for trainees
• Only Salaries Wages
• No overtime, benefits, or other costs
• Remains employed 60 days after

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Cash Contributions

• Additional funds or services provided paid for
  by the grantee
• 3rd party cash contribution
• to the grantee organization
• Allowable services under the grant

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In-Kind Contributions

• Donations
• Time
• Volunteers or paid non-grantee staff
• Services
• Equipment Supplies
• Space

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In-kind Contributions

• Costs not paid for by the grant or the grantee
• Allowable H1B costs services
• Requirements for determining value
• 29 CFR 97.24(b)(7)
• 29 CFR 95.23(c-h)

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Value of Contributions

• Time
• Volunteers
• 3rd Party paid staff
• Supplies Equipment
• Fair market value
• Space
• Rental rates
• Use allowances
• Depreciation

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Match Expenditures

• Verifiable and traceable
• Detailed valuation of 3rd party contributions
• Volunteer costs allocated appropriately
• Available for review or audit

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Records

• Source documentation to support claims
• Books of account
• Available for audit review
• Records available to support 3rd party
  contributions
• Verifiable from subgrantee records or
• Maintained by grantee
• Methods used to value in-kind

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Match Reporting

• STANDARD FORM 269
• Recipients Share of Net Outlays
• e. Third party (in-kind) contributions
• f. Other federal funds authorized for use
• h. All other recipient outlays
• i. Total recipient share of net outlays

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Questions?