Fiscal year 2009 TAA grant allocations

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2008/TEGL04-08acc.pdf

CLASSIFICATION
      EMPLOYMENT AND TRAINING ADMINISTRATION                   TAA
                  ADVISORY SYSTEM                              CORRESPONDENCE SYMBOL
             U.S. DEPARTMENT OF LABOR                          ONR
                  Washington, D.C. 20210                       DATE
                                                               October 28, 2008



TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 4-08

TO:           STATE WORKFORCE AGENCIES
              STATE WORKFORCE LIAISONS
              STATE TRADE COORDINATORS

FROM:         BRENT R. ORRELL /s/
              Deputy Assistant Secretary

SUBJECT:      Fiscal Year (FY) 2009 State Base Allocations and the Process for Requesting
              Additional Trade Adjustment Assistance (TAA) Program Reserve Funds

1. Purpose. To provide states with the formula methodology used in developing the Fiscal
   Year (FY) 2009 base allocations and to describe the process for requesting additional TAA
   program reserve funds for training, job search and relocation allowances.

2. References. The Trade Act of 1974, as amended; the Governor-Secretary Agreement; 2 CFR
   Part 225 (codifying OMB Circular A-87); 20 CFR Part 617; 29 CFR Parts 96, 97, 98, and 99;
   Training and Employment Guidance Letter (TEGL) 6-03 “Fiscal Year (FY) 2004 State
   Planning Estimates and Process for Requesting Additional Trade Adjustment Assistance
   (TAA) Funds for Training and Administration,” dated October 1, 2003 and TEGL 2-04
   “Trade Adjustment Assistance (TAA) Program Reserve Funds,” dated July 14, 2004.

3. Background. The Employment and Training Administration (ETA) revised its fund
   allocation process for the TAA program and implemented a formula-based methodology for
   distributing training funds on October 1, 2003, TEGL 6-03. This approach enables states to
   receive a base allocation at the beginning of the fiscal year. The formula has proven
   effective in allowing states to better plan and manage resources for addressing the
   employment and training needs of TAA-certified workers.

   The funding formula facilitates the fair and equitable distribution of available resources for
   training; encourages states to serve the greatest number of people with the resources
   available in the current fiscal year; provides an incentive for states to fund training plans
   through the end of the current fiscal year rather than mortgaging this year’s funds for next




 RESCISSIONS                                          EXPIRATION DATE:
 None                                                 Continuing

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   year’s needs; provides states with the ability to more effectively plan and manage the use of
   their TAA training resources; and is consistent with ETA’s goal to secure rapid, suitable, and
   long-term employment for adversely affected workers.

4. Overview of Funding Process. Pending TAA reauthorization legislation and/or FY 2009
   appropriation legislation, the attached base allocations assume the TAA program training
   cap will remain at $220 million. Should the TAA program appropriation amount change as
   a result of reauthorization, or be reduced as a result of a continuing resolution in lieu of
   reauthorization or a regular appropriation, the base allocations will be adjusted using the
   same methodology used to formulate the attached allocations which are equal to 75 percent,
   or $165 million, of $220 million. The factors used in determining each state’s share of the
   formula funds include previous year accrued expenditures and participant levels. The
   remaining 25 percent, or $55 million, should the funding levels remain the same, will be
   reserved for distribution to states experiencing large, unexpected layoffs or having training
   needs that exceed available funds.

   States must submit a fund request and demonstrate that at least 50 percent of all available
   TAA training funds have been accrued as expenditures, or otherwise demonstrate need, in
   order to access reserve funds. To apply for reserve funds, as well as job search and
   relocation allowance funds, states must use the Standard Form (SF) 424, Application for
   Federal Assistance (OMB Approval Number 3076-0006) and the ETA-9117, Trade
   Adjustment Assistance Reserve Funding Request Form (OMB Approval Number 1205-
   0275).

   An additional 15 percent will be added for program administration to any base allocation,
   reserve training funds or job search and relocation allowance funds awarded to states.

5. FY 2009 Fund Allocation Process. For FY 2009, the formula is the same as the formula
   established by TEGL 6-03 -- 75 percent of training funds are available to states by formula,
   and 25 percent will be held in reserve. The process is as follows:

   A. TAA Formula Funds: 75 percent of the assumed $220 million available for TAA
      training—or $165 million—is being distributed to states using the following formula:

       ƒ 50 percent of TAA formula funds, or $82.5 million, is being distributed based on
         accrued training expenditures reported for FY 2006, FY 2007 and the first two
         quarters of FY 2008 on the ETA-9130, U.S. DOL ETA Financial Report (OMB
         Approval Number 1205-0464) and successor to the SF-269, Financial Status Report,
         (OMB Approval Number 1205-0461), (i.e., the sum of each state’s accrued
         expenditures for training for FY 2006, FY 2007 and the first two quarters of FY 2008,
         divided by 2.5).

       ƒ 50 percent of TAA formula funds, or $82.5 million, is being distributed based on the
         average number of training participants for FY 2006, FY 2007 and the first two
         quarters of FY 2008 as reported on the ETA-563, Quarterly Determinations,
         Allowance Activities and Employability Services (OMB Approval Number 1205-0016)

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      (i.e., the sum of each state’s reported participants for FY 2006, FY 2007 and the first
      two quarters of FY 2008, divided by 2.5).

       With regard to participant data, each fiscal year’s participants are calculated by
       taking new participants reported as enrolling in training during that year and
       adding them to individuals reported in training on the last day of the prior fiscal
       year. Participant level data includes all trade-affected workers with an approved
       training plan, regardless of funding source.

   ƒ To minimize significant fluctuations in state funding from prior years, the formula for
     FY 2009 also contains the “hold-harmless” feature used since implementation of the
     formula. The hold-harmless factor ensures that each state’s base allocation is at least
     85 percent of the base allocation the state received in FY 2008.

   ƒ In those instances where the formula approach would have given states less than
     $100,000, those states will not receive a base allocation and will need to use WIA
     formula funds for TAA training and/or request TAA reserve funds in accordance
     with the procedures described in Section B.

The base allocations for each state are attached.

B. TAA Reserve Funds: The remaining 25 percent of the $220 million requested for TAA
   training—or $55 million—will be designated for reserve funding. Reserve funds will be
   distributed to states on an as-needed basis and are designed to provide monies to those
   states that experience large, unexpected layoffs or have training needs that are not met
   by their base allocation. In order to be eligible for TAA reserve funds, states must
   demonstrate that at least 50 percent of all available TAA training funds during FY 2009
   have been expended on an accrual basis, or otherwise demonstrate need. States
   requesting reserve funds must complete the SF-424 and ETA-9117 and submit them in
   accordance with instructions contained in TEGL 2-04.

   In addition to the criteria contained in TEGL 2-04, factors that will be taken into
   consideration during the review of these funding requests will include: the expenditure
   of FY 2009 base allocation funds; the expenditure of prior fiscal year TAA funds; the
   availability of WIA and other sources of funds; the number of participants currently
   enrolled in training; the number of participants with approved training plans who have
   not started training; the number of anticipated new enrollees; the number of petitions
   certified; the average take-up rate for training; the average training cost per participant;
   the average training duration; and the average training completion rate.

C. Job Search and Relocation Allowances: States may also request job search and
   relocation allowances for trade-affected workers who are unable to find employment
   within their local commuting area. These funds must be requested using the ETA-9117
   and may be submitted at any time or in combination with a request for reserve training
   funds.

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   D. TAA Program Administration Funds: States will continue receiving an additional 15
      percent of all base allocation, reserve, and job search/relocation allowances for program
      administration. The administrative funds will be included each time funds are obligated
      to states by ETA.

       The program administration allocations for each state are also included in the
       attachment.

   Consistent with the TAA Annual Cooperative Financial Agreement, ETA may recapture any
   funds that states are unable to utilize within a reasonable period of time, but only after
   consultation with and appropriate notification to state officials.

6. Hold Harmless. In the report entitled, “Trade Adjustment Assistance: Changes to Funding
   Allocation and Eligibility Requirements Could Enhance States’ Ability to Provide Benefits
   and Services” released in May 2007, the Government Accountability Office (GAO) found
   that “a particular problem with Labor’s allocation process is the hold harmless policy, which
   guarantees that each state receives no less than 85 percent of what it received in the previous
   year.” ETA acknowledges that it may be time to reevaluate this policy, which was intended
   to minimize significant fluctuations in state funding from prior years. ETA did not act to
   change the hold harmless policy for the FY 2009 base allocations, due to the fact that
   pending legislation reauthorizing the TAA program dealt directly with the factors included
   in the formula. If legislation that specifically addresses the factors included in the formula is
   not enacted during FY 2009, ETA will consider revising or eliminating the hold harmless
   policy for the FY 2010 base allocations.

7. Program Reporting. The formula approach to distributing TAA funds emphasizes the
   importance of accurate and timely reporting of training participant and expenditure data on
   the ETA-563 and the ETA-9130. Reported data on these forms are critical in determining the
   level of funds states will receive each year for serving trade-affected workers. It is in each
   state’s best interest to ensure accuracy and timeliness of reported data in the ETA-563, ETA-
   9130, and the Trade Act Participant Report (TAPR) (OMB Approval Number 1205-0392).
   Data on the TAPR are used to derive the average training duration and the training
   completion rate when evaluating state requests for TAA reserve funds. In addition,
   accurate information on the SF-424 and ETA-9117 submitted by states is essential for
   assessing requests for TAA reserve funds and job search and relocation allowances.

8. Action Required. States should ensure that all trade and workforce investment program
   staff are informed and knowledgeable of this funding methodology.

9. Inquiries. States should direct all inquiries to the appropriate ETA regional office.

10. Attachment. FY 2009 State Base Allocations and Administrative Allotments.

Attachment PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2008/TEGL04-08a1.pdf

Attachment
  Fiscal Year (FY) 2009 TAA Training Base Allocations and Administrative Allotments

                                       FY 2009 Training Base          FY 2009 Administrative         Total FY 2009 TAA Base
              State                         Allocation                      Allotment*                     Allocation**
 Alabama                                             $2,349,702                        $352,455                     $2,702,157
 Alaska                                               $318,870                           $47,831                      $366,701
 Arizona                                             $1,499,072                        $224,861                     $1,723,933
 Arkansas                                            $2,773,947                         $416,092                    $3,190,039
 California                                          $8,582,341                       $1,287,351                    $9,869,692
 Colorado                                            $1,297,962                         $194,694                    $1,492,656
 Connecticut                                         $1,766,862                         $265,029                    $2,031,891
 Delaware                                                    $0                               $0                            $0
 District of Columbia                                        $0                               $0                            $0
 Florida                                             $2,057,653                         $308,648                    $2,366,301
 Georgia                                             $3,345,312                         $501,797                    $3,847,109
 Hawaii                                                      $0                               $0                            $0
 Idaho                                               $1,467,992                        $220,199                     $1,688,191
 Illinois                                            $6,859,893                       $1,028,984                    $7,888,877
 Indiana                                             $6,117,115                        $917,567                     $7,034,682
 Iowa                                                $3,140,002                         $471,000                    $3,611,002
 Kansas                                              $1,704,649                        $255,697                     $1,960,346
 Kentucky                                            $4,482,329                        $672,349                     $5,154,678
 Louisiana                                            $376,196                           $56,429                      $432,625
 Maine                                               $3,076,832                         $461,525                    $3,538,357
 Maryland                                              $770,432                         $115,565                      $885,997
 Massachusetts                                       $5,400,240                        $810,036                     $6,210,276
 Michigan                                            $8,364,847                       $1,254,728                    $9,619,575
 Minnesota                                           $2,460,025                         $369,004                    $2,829,029
 Mississippi                                         $1,274,933                         $191,240                    $1,466,173
 Missouri                                            $4,039,994                        $605,999                     $4,645,993
 Montana                                              $681,335                          $102,200                      $783,535
 Nebraska                                              $430,950                          $64,643                      $495,593
 Nevada                                                $155,696                          $23,354                      $179,050
 New Hampshire                                         $491,220                          $73,683                      $564,903
 New Jersey                                          $2,077,070                         $311,561                    $2,388,631
 New Mexico                                            $286,329                          $42,949                      $329,278
 New York                                            $3,029,905                         $454,486                    $3,484,391
 North Carolina                                    $16,640,616                        $2,496,092                   $19,136,708
 North Dakota                                                $0                               $0                            $0
 Ohio                                                $5,637,647                        $845,647                     $6,483,294
 Oklahoma                                            $1,917,085                         $287,563                    $2,204,648
 Oregon                                              $4,847,072                         $727,061                    $5,574,133
 Pennsylvania                                      $11,092,493                        $1,663,874                   $12,756,367
 Puerto Rico                                                 $0                               $0                            $0
 Rhode Island                                        $1,016,893                         $152,534                    $1,169,427
 South Carolina                                      $6,292,481                        $943,872                     $7,236,353
 South Dakota                                          $510,905                          $76,636                      $587,541
 Tennessee                                           $3,124,250                         $468,638                    $3,592,888
 Texas                                               $8,280,256                       $1,242,038                    $9,522,294
 Utah                                                $1,114,248                        $167,137                     $1,281,385
 Vermont                                               $285,935                          $42,890                      $328,825
 Virginia                                            $5,357,066                         $803,560                    $6,160,626
 Washington                                          $8,817,177                       $1,322,577                   $10,139,754
 West Virginia                                       $2,278,576                         $341,786                    $2,620,362
 Wisconsin                                           $7,107,595                       $1,066,139                    $8,173,734
 Wyoming                                                     $0                               $0                            $0
 US Total                                         $165,000,000                       $24,750,000                  $189,750,000

    * Each state’s administrative allotment represents 15% of its FY 2009 base allocation.
** Each state’s allocation represents the sum of its base allocation and administrative allotment.