Faqs on Arra Neg _update 4-28-10

8/9/2019 Faqs on Arra Neg _update 4-28-10

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5) Must all funding be spent by 09/30/11 or can funding be carried over past that date?

9/30/11 was our original end-date for this project, DELEG isarranging for a no-cost extension to 6/30/12. The funding must bespent by 6/30/12.

6) First, the Draft PI indicates that core & intensive services are allowable under thisgrant as are wrap-around services for Trade-Eligible participants. I want to verifythat staff costs are includable in these allowable expenditures.

Yes, staff costs associated with the implementation of this program areallowable expenditures. Staff costs that do not involve dealing directlywith participants would be categorized as administrative costs, staff timespent dealing directly with participants (case management, for instance)are program costs.

7) If direct staff cost is allowable, can those dollars be reported collectively onAttachment 4?

Yes. Attachment 4, the Obligation Form, should be used todocument contractual obligations. Contractual obligations includetraining costs, core, intensive, supportive services and MWAadministrative costs for the current fiscal year only.

8) For the Employer Data Form is there an approval process in place or is it simply amatter of filing a the paperwork in order to document that the participant(s) are partof a closure/downsizing? If there is an approval through DELEG, can you estimatewhat the turnaround time might be for that?

There is no pre-approval process in place for the Employer DataForm. MWAs must simply fill out the paper work to document thatthe participant(s) are part of a dislocation. It is the MWA projectoperators responsibility to verify that a participants dislocation datefalls within the 11/1/08 9/30/10 time period. Please email the formto [email protected].

9) The Obligation and Waiting List forms do they need to contain both training costsand estimated additional costs such as staff and administration?

As we discussed in the regional NEG meeting, the obligation andwaiting list reports need only to include training costs at a minimum.However, if you are able to estimate a cost per participant for theother types of costs, it would be helpful to DELEGs effort todemonstrate an accurate obligation picture to US DOL to support arequest for the second increment of funds.


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10) Do we have to report administrative costs on monthly basis? Why are projectoperators being asked to estimate administrative dollars on the obligation andwaiting list reports?

Admin costs should be reported monthly if at all possible. We are

trying to eliminate as much lag time as possible to obtain the nextincrement of funds from US DOL, and if project operators wait untilthe end of the quarter to report instead of doing it monthly, ourexpenditure rates will be negatively impacted.

11) When should training obligations be recorded?

MWAs should ensure training obligations are recorded in the monththey would be accrued (the point of no return for the funds, forexample the drop/add date).

12) Are stipends and performance-based payments are allowable costs?

No, these are not allowable costs to charge to an NEG.

13) Can out-of-state companies be added to an REI NEG?

The only case in which the inclusion of an out of state firm might beincluded would be if the worker in question worked for the firm in afield office or home office in one of the Michigan Recovery Act NEGareas and performed most (51% or more) of their work in the state.

Please keep in mind that an eligible person's former work placeneeds to have been in the regional boundaries of one of theRecovery Act NEG areas. If you have a question about including anout-of-state firm, please contact your Rapid Response Workforceconsultant before enrolling the participant. Our number is (517) 373-6234.

14) A participant started module / semester based training prior to 10/1/2009. Thefall semester started prior to 10/1/2009 and the participant attended, but we wereunable to fund it at the time. As long as this was part of the participantsapproved training plan, are we able to fund this module / semester today?

As long as the participants registration date predates the expenditure, andthe expenditure occurs after the project start date (10/1/09), the expenditureis allowable. For the type of participant described above, the projectoperator could charge pro-rated costs from the registration date forward.

15)One local area, in particular, (Career Alliance) is dealing with many participants(as of now about 50) that live in the Flint area and would like to receive services


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from Career Alliance, but were dislocated from a company located within adifferent REI grant, typically Oakland or Wayne County. Guidance up tonow states that the person is only eligible for services from the REI region wheretheir dislocation occurred. This is very problematic, though, for participants wholive a great distance from their former employer. This situation reflects the fact

that many people commuted great distances for their jobs prior to dislocation, aswell as the fact that after being laid off, many were forced to move in with friendsor relatives who reside in a different part of the state. We discussed the idea ofone local area obtaining reimbursement from another as a way of ensuringthe participant's costs are tied to the appropriate REI, however, this wasperceived to be a logistical and political nightmare at the local level.Complicating this situation is the fact that some locals are already out of NEG$ (i.e. it's fully obligated) so that, for example, the person living in the Thumb whowas forced to go to Oakland County for services would be put on a waitinglist even though they could have received services immediately in theThumb. How can we resolve this situation?

The REI grant in the region where the person lives should simply add theemployer layoff event to their list of events covered under their own grant,even though the employer was located in a different region and is listed asa covered event in that other region. In other words, the regional impact ofthe layoff can affect more than one region. This does not require amodification. Then they can serve the person from their own grant andnearer to the person's home rather than send them trekking across thestate.

16) There was some discussion at our NEG training in Holland regarding the wife of

a NEG qualified dislocated worker as being qualified under NEG. Can you pleaseclarify/confirm?

A spouse (such as a stay at home mom or dad) of a worker who wasdislocated within the ARRA NEG region and whose dislocation occurred inthe eligible time frame (dislocated from 11/1/08 to 9/30/10) can be aparticipant in the ARRA NEG. An employer data form entry on thespreadsheet we provided for the spouse's dislocation should be filled outand submitted to DELEG RR and that info should also go into the spouse'sfile to give supporting documentation of eligibility.

17) Can you clarify what it means that a client needs to be enrolled in NEG or avoucher signed by Sept. 30, 2010? Does the client have to actually start theirtraining by 9/30/10. Let me give you an example: we have a client who hasenters our service center sometime before 9/30/10 who is eligible for NEG.However the training they want to take does not start until Jan. 2011. We cansign a voucher for them and enroll them in MIS before 9/30/10 but they will notactually be sitting in training until Jan. 2011. Is this eligible?


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In the NEG means that that youve enrolled them into the MIS system andyouve checked the box to enroll them into the NEG project. This actionneeds to take place on or before 9/30/10. They do not need to have startedtheir training.

Enrollment into the NEG is not predicated on just training for example, anoperator would not be allowed to pay for training for a TAA certifiedparticipants, but can pay for wrap around services with NEG funds. Itmight be that an NEG enrollee doesnt need or doesnt want any training,but just wants to get some core and intensive services and supportiveservices, which can be paid for with NEG funds. The fact that they neverenrolled in training does not render them ineligible.

Yes, your example would fit as an eligible cost as long as their dislocationoccurred in the window of eligibility (11/1/08 through 9/30/10) for thisproject and you enrolled/co-enrolled them into the project on or before

9/30/09.

Faqs on Arra Neg _update 4-28-10

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