Using separate YouthBuild grant awards

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                WIOA/YouthBuild
               ADVISORY SYSTEM                           CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                       OWI-DYS
             Washington, D.C. 20210                      DATE
                                                         July 12, 2016


ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 2-10,
                Change 1

TO:             STATE WORKFORCE AGENCIES
                STATE WORKFORCE LIAISONS
                STATE WORKFRCE ADMINISTRATORS
                STATE AND LOCAL WORKFORCE INVESTMENT BOARDS
                ALL YOUTHBUILD GRANTEES

FROM:           PORTIA WU /s/
                Assistant Secretary

SUBJECT:        Further Clarification on the Use of YouthBuild Funds Provided by Separate
                Year Funding Appropriations

1. Purpose. To further clarify the use of YouthBuild funds expended under each Program
   Year’s (PY) grant awards.

2. References.
   • Workforce Innovation and Opportunity Act (PL 113-128 July 2014),
      https://www.gpo.gov/fdsys/pkg/PLAW-113publ128/pdf/PLAW-113publ128.pdf
   • YouthBuild Final Rule, 20 CFR Part 672,
      https://www.federalregister.gov/articles/2012/02/15/2012-2373/youthbuild-program
   • Notice of Availability of Funds and Funding Opportunity Announcement (FOA) for
      YouthBuild Grants, FOA-ETA-16-10,
      https://www.doleta.gov/grants/pdf/FOA-ETA-16-10.pdf

3. Background. The Department of Labor (DOL) has awarded grants to organizations to
   operate YouthBuild programs since PY 2007. These organizations are funded for a three-
   year program cycle that includes two years of core program services and one year of required
   follow-up (including supportive services and tracking of participant outcomes). Many
   YouthBuild programs receive a new grant award every other program year (e.g. PY 2007, PY
   2009, PY 2011, etc.) to fund a new and separate grant cycle of two years of program services
   and one year of required follow-up. This Training and Employment Guidance Letter (TEGL)
   clarifies the use of funds and enrollment of youth in overlapping program cycles (e.g. PY
   2013 and PY 2015).

4. Enrollment of Youth. If an organization receives a YouthBuild grant that overlaps with a
   previous YouthBuild program cycle, they must have a new and separate program cycle up
   and running with new and separate participants. Youth enrolled and served with previous

 RESCISSIONS                                            EXPIRATION DATE
 None                                                   Continuing


   program cycle funds may not be served with any portion of YouthBuild funds from
   subsequent grant awards simultaneously. If a youth dropped out of a previous program
   cycle for any reason prior to completion or graduation from the program, and if that youth
   was exited as an unsuccessful completer in DOL’s Web-based Management Information
   System (MIS), then he/she could be considered a new enrollee in the subsequent grant cycle.

   As an example, Grantee X received a YouthBuild award in 2013 and in 2015. Participant A
   enrolled in late 2014 and received services from the 2013 award, while Participant B enrolled
   in late 2015 and received services from the 2015 award. Participant A and Participant B may
   work on the same work site and attend the same classes and training sessions, but Grantee X
   must track and carefully distinguish expenditures of grant dollars for teacher time, work site
   trainer costs, construction materials, and other shared costs based on the number of
   participants from each grant receiving the services. In this example, Grantee X would charge
   Participant A’s costs to the PY 2013 award, whereas the grantee would charge Participant
   B’s costs to the PY 2015 award. Grantees should be properly budgeting and allocating for
   grant costs in order to fully serve participants within one grant class. If Grantee X’s PY 2013
   grant award funds have been depleted, Grantee X may continue to serve Participant A using
   Grantee X’s PY 2015 funding only by exiting Participant A as an unsuccessful exiter from
   the PY 2013 grant’s MIS and subsequently reenrolling that participant as a new participant in
   the PY 2015 grant MIS.

   It is the responsibility of the grantee to coordinate the cost allocation and budgetary tracking
   necessary to run programming for two separate groups of youth participants simultaneously
   if necessary and to ensure that funding for each program is accounted for separately and
   appropriately within each grant award. The grantee is responsible for separately tracking
   each grant award. The grantee must provide separate financial (ETA 9130), quarterly
   performance, and narrative reports covering the participants served under each grant award.
   A new ETA-9130 Form is required for each grant award. More than one ETA-9130 Form
   may be required if a grant award includes monies from more than one appropriation or
   Payment Management System subaccount number. Please also be advised that OMB has
   recently approved a new ETA-9130 Form which is expected to be implemented shortly. A
   copy of the new ETA-9130 form can be found at
   https://www.doleta.gov/grants/financial_reporting.cfm.

5. Inquiries. Questions on this TEGL may be addressed to the appropriate ETA regional
   office.