Reg Workforce Development Board agenda 071901

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Federal Register /Vol, 66 , No . 105 / Thursday , May 31 , 2001 / Notices 29639 integrating the common activities and program has normally incurred to the document . While one of the costs of the several partner programs provide a service that becomes a objectives of this guidance is to should result in reduced costs , common service / activity in the One - emphasize that cost allocation and including reduced administrative costs , Stop environment will be approximately resource sharing are two distinctly for the individual partner programs . the same as it costs each program to different concepts , there are many Whatever the nature. of the shared cost provide the service separately , it is also instances where it is almost impossible (program or administrative , direct or quite possible that the efficiencies and to talk about one of the concepts indirect, allowable or unallowable ) , economies of scale will result in a lower without reference to the other. Cost each partner program must be assessed cost . However , the normal historical allocation is the measurement of actual its proportionate. share. based on the cost of delivery of a particular service or costs based on benefits received . benefit received by that program . Also , activity is not a proper allocation base . Resource sharing is the concept of how this paper. clearly indicates. that no A cost allocation base should be. a factor these costs will be paid for or funded . partner may use federal funds to pay for that has a causal relationship to the The two concepts are intricately a cost in violation of its statutory and costs being allocated and the benefits interrelated . regulatory provisions . Therefore , it may received by each program . We received a few comments that be necessary for local One- Stops to One commenter indicated that the appear to. take exception to the ETA supplement the federal resources with guidance needs to address the propriety vision of integration of partner program non -federal resources . While it may be and impact of modifications to the cost services in the One- Stop environment . necessary for. the partner programs to allocation and resource sharing Other comments expressed concern identify the limits of their ability to methodologies . Discussion of this about the inference that integration was contribute to the common costs of the subject has been added to the third a future expectation while co -location One- Stop , in no case would it be proper paragraph of the section titled Funding and coordination of services was most for a predetermined budgeted amount to or Paying for a Partner ' s Allocated Share typical at the present time . The concern be set as the actual cost for any program . of One - Stop Costs . The guidance appears to be that local One- Stop Cost allocation is always based on explains that cost allocation and systems and centers will not move actual costs , which maybe greater. or resource sharing methodologies should toward integration if the guidance leads less than the budget planning levels , be modified to reflect actual experience them to. believe co -location and One commenter thought that the and that such modifications ought to coordinated services meets ETA ' s statement in this guidance. that the One- occur as soon as the need is recognized , current expectation. ETA ' s vision for Stop budget does not need to be A number of commenters expressed this program has not changed . While included in the MOU was contrary to concern about whether the guidance other models are. acceptable ,. ETA will the provisions at WIA section 121 ( c) ( 2 ) was meant to apply to One- Stop centers continue. to work with States and local and the regulation at 20 CFR 662 . 300 . only or to the One- Stop system as a areas to help them realize the benefits Both of those provisions. require that the whole . The guidance included herein is of a fully integrated system . Language MOU. include. a description of the intended to apply to both . One has been added to encourage the methods for. funding the costs of commenter requested clarification as to movement toward integration , even if program services and the operating costs whether the term One- Stop partners. is done in phases . The changes are of the One - Stop , but they do not require meant to include only the required intended to eliminate. any the inclusion of a budget in the local partners or all One- Stop partners . The misperception that ETA is encouraging MOU . If a local area chooses. to. include term is meant to include all of the One- Stop systems to stop short of a fully its One- Stop budget in the MOU , it may partners for a given local area . In integrated system . do so . However ,. care should *be taken to addition to the required One- Stop A couple of commenters suggest that assure that the MOU. is written so as not partners , WIA section 121 (b) ( 2 ) the paper identify -which funding to require modification every time there identifies possible additional partners streams can be used to cover costs of is a need to adjust or correct the budget , which may include entities that operate State and Local Workforce Investment which could happen frequently . Federal , State , local and private sector Boards established under WIA . Such One commenter questioned whether programs . This commenter also costs are not typically common costs of the discussion based on OMB Circular wondered -what basis exists for requiring the One - Stop system but rather are costs A- 87 (Cost Principles for State , Local a partner program that is not financed of the. WIA program . However , it is and Indian Tribal Governments ) , with any Federal funds to bear its fair possible. that some boards may incur Attachment A , paragraph C . 3 . c . and share of the common costs of the One - costs for activities that extend beyond ASMB C-10 , the implementation guide Stop . If any program wants to be a the role that title I of WIA requires of for OMB Circular A-87 , meant that it partner in a local One - Stop system , it them . The costs of such activities may was proper to allocate funds based on should be included in the MOU for the benefit other partner programs and how much funding individual program local area . To the extent that each should be treated as shared costs partners have available . It appears that partner benefits from the common costs allocated to the partner programs based the commenter has misinterpreted these of the One - Stop , it should pay for the on benefits received , provisions ; neither OMB Circular A-87 allocable share attributable to its A couple of commenters asked if there nor ASAP C-10 say that costs can be program . The same commenter asks would be more guidance on in-kind allocated and paid for based on whether the Federal funding agencies contributions . This guidance addresses available budget amounts . Expenditures are either an express or implied partner the proper allocation among the partner reported under Federal programs may thus making bilateral MOUs trilateral programs of common costs incurred in not be based on budgeted costs . agreements . The Federal funding a One- Stop environment . In- kind One commenter suggested that the agencies are not partners to the local contributions ; as discussed in the allocation base for any service normally area MOUs . matching or cost sharing sections of the provided by a partner program should There were a couple of comments uniform administrative requirements be the normal historical cost of that which suggested that the concepts of found in OMB Circulars A- 102 and A— partner providing the service . While it cost allocation and resource sharing 110 , are donations from third parties . is possible that the cost that a particular appear to be commingled throughout They are not to be confused with