Voter registration costs in the American Job Center network, Change 2

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                WIOA
               ADVISORY SYSTEM                           CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                       OWI
                                                        DATE
             Washington, D.C. 20210
                                                        July 8, 2025

ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 08-21,
                CHANGE 2

TO:             STATE WORKFORCE AGENCIES
                STATE WORKFORCE LIAISONS
                STATE WORKFORCE DEVELOPMENT BOARDS
                LOCAL WORKFORCE DEVELOPMENT BOARDS
                ALL AMERICAN JOB CENTER PROGRAMS

FROM:           LORI FRAZIER BEARDEN
                Acting Assistant Secretary

SUBJECT:        Stopping the Use of Federal Funds in Conducting Voter Registration within the
                American Job Center Network

1. Purpose. To inform states, local areas, and other recipients of Department of Labor’s (DOL)
   Employment and Training Administration (ETA) funds that ETA Federal financial assistance
   awards cannot fund or reimburse the costs of voter registration activities conducted within
   the American Job Center (AJC) network.

2. Action Requested. States, local areas, and other grantees are directed to review their
   policies, processes, and procedures, including applicable memoranda of understanding and
   cost sharing agreements, to ensure compliance with this Training and Employment Guidance
   Letter (TEGL).

3. Summary and Background.

   a. Summary – States, local areas, and other grantees cannot allocate funds for voter
      registration activity costs to their ETA grants.

   b. Background – The public workforce system, under the Workforce Innovation and
      Opportunity Act (WIOA), is designed to help job seekers access employment, education,
      training, and support services to succeed in the labor market and to match employers with
      skilled workers. WIOA funding and other ETA-funded activities should adhere closely
      to their intended mission and be directly tied to their authorized activities. WIOA
      funding can be used for a wide variety of activities that support employment and training
      of American workers or the skilled labor demands of American employers but cannot be
      used for purposes unrelated to the statute. Utilizing ETA-provided resources for voter
      registration redirects programs away from their core workforce development mission. To
      realign AJC programs and reinforce worker-centric priorities, ETA rescinded TEGL No.
  RESCISSIONS                                            EXPIRATION DATE
  None                                                   Continuing

       08-21, Providing Access to Voting Through the American Job Center Network on May 2,
       2025. This guidance replaces TEGL No. 08-21 and supports AJC compliance with
       Executive Order 14248, Preserving and Protecting the Integrity of American Elections.

4. Voter Registration Activities Are Unallowable Costs under WIOA. The costs of
   conducting voter registration activities are not allocable to ETA funding. Voter registration
   activity costs incurred after the issuance of this guidance and identified during ETA’s federal
   management and oversight of grant awards will result in disallowed costs.

   a. Covered Programs - This guidance applies across all ETA-funded programs, unless an
      exception is provided in applicable federal laws, regulations, or subsequent DOL
      guidance. Several ETA programs, including the WIOA Title I Youth Program,
      YouthBuild, Indian and Native American Supplemental Youth Program, National
      Farmworker Jobs Program, and Reentry Employment Opportunities programs include
      provisions intended to promote the positive leadership development of youth participants;
      the WIOA Youth program specifically includes Leadership Development as a required
      element, which sometimes includes the discussion of voting as a form of community and
      civic engagement. This guidance does not change the WIOA Youth elements or change
      any participants’ right to vote. However, grantees may not allocate costs for voter
      registration activities to their ETA grant, as voter registration activities are outside the
      purposes of ETA’s grants.

   b. Shared Space and Co-located State and Local Services - One of the founding
      principles of the AJC network is co-location of various employment and related services
      to provide a “one-stop” service model for both workers and employers. In implementing
      the “one-stop” approach it has become common for various federal, state, and local
      programs to be co-located within AJCs and for AJC centers, themselves, to be housed
      within larger government facilities, such as state universities or government centers.
      Furthermore, some AJC staff members’ compensation may be allocated across a
      combination of federal, state, or local programs. This guidance only applies to the ETA
      portion of funds in such cost sharing arrangements.

   c. Conformity with Federal Laws - Nothing in this guidance shall be construed to impair
      or otherwise affect the authority granted by law, including the National Voter
      Registration Act of 1993, to states or local areas.

5. Inquiries. Please direct inquiries to the appropriate Regional Office.

6. References.

       •   The National Voter Registration Act of 1993, codified as amended at 52 U.S.C. §§
           20501-20511;
       •   Workforce Innovation and Opportunity Act (WIOA), Pub. L. No. 113-128, 128
           STAT. 1425, 1573-1576;
       •   20 CFR 681.530, 20 CFR 684.310, 20 CFR 685.370;

      •   Executive Order 14248, Preserving and Protecting the Integrity of American
          Elections, issued March 24, 2025; and
      •   TEGL No. 08-21, Change 1, Recission of Training and Employment Guidance Letter
          (TEGL) No. 08-21, Providing Access to Voting Through the American Job Center
          Network, issued May 2, 2025.

7. Attachment(s). N/A