TEGL-17-18 FAQs 5.21.19.pdf

Posted: May 21, 2019

FREQUENTLY ASKED QUESTIONS (FAQ)

TEGL-17-18: AVAILABILITY OF PROGRAM YEAR 2018 FUNDING FOR

STATE APPRENTICESHIP EXPANSION

ELIGIBLE APPLICANTS

1) What organizations can apply for these grants?

• As indicated in the TEGL Section 5: Eligible Applicants, organizations eligible to receive funding under this announcement are State Agencies (“e.g., State Workforce Agency eligible for funding under Title I of the Workforce Innovation and Opportunity Act (WIOA), a State Educational Agency, or a State

Apprenticeship Agency (SAA)”) designated via a letter from the Governor or Chief Elected Official of that

State as the applicant. States, as defined at 29 CFR Section 29.2, mean “any of the 50 States of the

United States, District of Columbia, or any Territory or possession of the United States.” All States are encouraged to apply regardless of apprenticeship administration structure or previous State

Apprenticeship Expansion (SAE) funding.

2) Can a State with an apprenticeship system that has not received previous State Apprenticeship Expansion

(SAE) funding apply?

• Yes. This new funding vehicle is open to all States.

3) Can a State (or Territory) with no previously existing apprenticeship infrastructure apply?

• Yes. All States and Territories were included in the allotment in order to provide the opportunity to obtain funding to begin constructing an apprenticeship framework and infrastructure where none currently exists.

4) Does the application require a letter from a State’s Governor or Chief Elected Official?

• Yes. It is essential that the State Leadership designate the State Agency to apply for this discretionary funding to facilitate strong coordination of apprenticeship expansion projects within a State, and in order to avoid multiple applications from a State. ETA will award funds to only one agency in a State. If

ETA receives applications from multiple agencies that have letters designating them as the applicant, only one of these agencies will receive an award. ETA will consult with the Governor or Chief Elected

TEGL-17-18 FAQs

Official in determining which agency will receive the award. See TEGL Section 5: Eligible Applicants, Section 9.a.: Application Submission-Required Documents, and Attachment VII: Required Governor or

Chief Elected Officer Letter.

5) Does this State apprenticeship funding replace the previous State Apprenticeship Expansion (SAE) grant initiative?

Yes. Through this new program, ETA will offer States an allotment determined by a formula. To receive the allotment, States must submit the application materials required by TEGL 17-18.

6) Can Native American/American-Indian Tribes apply?

• Not at this time. However, we encourage Tribes to contact their State representatives to initiate conversations regarding how they can partner with currently eligible entities.

7) Can Workforce Development Boards (WDBs) apply?

• Only in some States. Generally, WDBs are not Statewide Agencies, but if yours is, contact your

Governor’s Office to determine who the designated Agency is and reach out to them to discuss getting involved in the application development.

8) Can my 510(c)(3) apply?

• No, but ETA encourages you to keep an eye on Apprenticeship.gov for the list of awardees, and contact your State Agency to explore partnership opportunities.

AWARD INFORMATION

9) When are applications due?

• The deadline for submissions is June 3, 2019 at 11:59:59pm. Applicants should begin the process early enough to allow adequate time for complete application submission to grants.gov prior to the deadline.

See TEGL Sections 6: Award Information, 9: Application Submission and 17: Action Requested. Any application submitted that includes the requisite SF-424, SF-424A, and a project narrative will be considered for funding, subject to conditions upon award at the Grant Officer’s discretion.

10) Are extensions are available?

• Extensions will not be granted, but any submitted application including the required SF-424, SF-424A, and project narrative will be considered for funding, subject to conditions upon award at the Grant

Officer’s discretion.

11) Where do we apply?

• See TEGL Section 9.b: Grants.gov Submission Process.

12) How long is grant period of performance?

• Section 9: Application Submission of the TEGL states "ETA plans to award these grants with a 36-month period of performance", with a start date of July 1, 2019. Grantees have until the end of the period-of-performance to obligate funds. All obligated funds must be liquidated no later than 90-days after the end of the period-of-performance.

PROGRAM REQUIREMENTS

13) Are there minimum requirements for the number of grant staff? If so, how much of grant staff’s time must be dedicated to grant projects?

• Yes. To adequately meet the goals of these grants, applicants must have the minimum number of staff

(based on the funding amount allotted) needed to successfully manage/execute the award activities

(TEGL Attachment III – Project Narrative Required Elements). All grants must have at least one (1) Full

Time Equivalency (FTE) 100% dedicated to the management/execution of this award. ETA requires additional FTEs depending on the amount of the grant award; any additionally required FTEs may be

'split' between multiple positions, as it aligns with program design (i.e., two (2) persons both working

0.5 FTE on this project, would be equal to one (1) 100% FTE).

Again, however, at least one member of the grantee’s staff must be 100% dedicated to the management/execution of this award, regardless of the award amount. Please see TEGL Change 1.

14) Do FTEs have to be paid out of grant funds?

• No, while personnel is an allowable cost under these grants, required FTE salaries or other personnel can be leveraged from other sources. Regardless of how an applicant plans to pay for required staff, the budget narrative and project narrative require applicants to indicate the source of funding for all required FTEs. Regardless of the source of funding, grantees must meet the minimum staffing requirements discussed above and in TEGL Change 1, and the Uniform Guidance provisions regarding staffing still apply.

15) Must I use grant funds to pay required FTEs’ salary and fringe benefits?

• No. FTE and other personnel salaries/fringe can paid with grant funds or can be leveraged from other sources allowable under the Uniform Guidance. Please note, the source of salary/fringe funding does not change the minimum number of FTEs (please see any published TEGL changes/amendments), and the Uniform Guidance remains applicable.

16) Do required FTEs have to be newly hired staff?

• No. FTEs can be new or existing personnel. DOL strongly encourages staffing grant projects with personnel who have appropriate, current apprenticeship programming knowledge and experience to support grant projects. An applicant’s staffing plan must also describe any additional staff beyond the minimum FTEs required by TEGL Change 1 and describe this additional staff’s apprenticeship programming experience.

17) Why is there a minimum number of FTEs?

• Adequate staffing capacity is essential to properly executing the technical, managerial, and administrative activities of these grants.

18) Is our staffing plan limited to the required number of FTEs?

• No. Grantees are encouraged to staff grant projects with more staff than minimum FTEs, and applicants must describe these additional staff in their staffing plan.

19) Are FTEs limited to grantee State staff or could they be a contract hires? Or WIOA partner staff assigned to the project?

• Staff can be contractors or the staff of WIOA partners. Required FTEs should, however, be integral grant staff whose primary job function/responsibility is related to this apprenticeship grant.

20) Are there minimum requirements for the number of apprentices to be served?

• Yes. Based on the amount of funding allotted, an entity must enroll at least the number of minimum participants in a Registered Apprenticeship program as grant participants before the end of the period of performance as indicated in the TEGL on page 8 and in Attachment III – Project Narrative Required

Elements. The minimum performance target refers to the number of eligible participants enrolled after

July 1, 2019 receiving training assistance through this grant award, or an eligible participant enrolled after July 1, 2019 in a Registered Apprenticeship.

21) Is the minimum number of participants a ‘completed’ target or a ‘placement’ target?

• The minimum-participant target is the number of participants enrolled in Registered Apprenticeship no earlier than July 1, 2019 and no later than the end of the period-of-performance for this grant.

22) Do participants have to meet WIOA eligibility requirements?

• No. There is no requirement that participants meet WIOA eligibility requirements. Partnership, coordination and/or integration with the WIOA system is, however, strongly encouraged. Please note

Section 13.B: Quarterly Performance Reports of the TEGL which states, “Performance reporting for these grants will align with the WIOA performance reporting requirements.”

23) Are pre-apprentices counted towards the participants served target for this grant?

• No, pre-apprentices cannot be counted towards meeting the participants-served target for this grant.

As outlined, however, in Section 7: Required Activities – Program Level Activities of the TEGL:

“The development of pre-apprenticeship programs and other on-ramps to apprenticeship to help support the enrollment of apprentices, for example through direct entry from a pre-apprenticeship into a RAP as a means of selection. For expenditures to be allowable, pre-apprenticeship programs must meet the definition and framework established through Training and Employment Notice No. 13-12, Defining a Quality Pre-

Apprenticeship Program and Related Tools and Resources, available at:

https://wdr.doleta.gov/directives/corr_doc.cfm?docn=5842.”

https://wdr.doleta.gov/directives/corr_doc.cfm?docn=5842

24) As a grantee, must I conduct all required system-level activities described in the TEGL?

• Yes. Grantees must use funds to conduct allowable activities from the list of System-Level and Program-

Level activities on pages 6 and 7 of the TEGL. As stated in the TEGL, DOL believes these allowable activities are required to accomplish the following:

• Fully integrate apprenticeship into state workforce development, education, and economic development strategies and programs;

• Support the rapid development of new registered apprenticeship programs and/or the significant expansion of existing registered programs;

• Support the development and recruitment of a diverse pipeline of apprentices;

Build state capacity to make it easier for industry to start registered apprenticeship programs and for apprentices to access opportunities.

MISC.: SUB-AWARDS; ACTIVITIES; AND EVALUATION

25) The TEGL does not directly identify restrictions on sub-awards, are they allowed, or not?

• Sub-awards, both sub-contracts and sub-grants, are allowable under this opportunity.

26) Can applicants use these funds to add new elements or strategies to existing state apprenticeship activities?

• Yes, but for existing SAE grantees, proposals must adhere to the Uniform Guidance prohibiting monies from two different vehicles being spent on the same activity. It is expected, however, that some activity from previous grants would continue. Applicants are encouraged to include activities that utilize new strategies to further integrate apprenticeship within the workforce system, and even further expand activity into new industries nationwide.

27) What additional information can you provide regarding the evaluation?

• There is no additional information regarding evaluation beyond that which is provided in the TEGL.

ETA will update this document as needed.