SCSEP technology implementation grants for 2023

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 SCSEP
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OWI-DNPTTA
             Washington, D.C. 20210                       DATE
                                                          January 24, 2024

ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 08-23

TO:             SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM (SCSEP)
                GRANTEES
                STATE AND TERRITORIAL GOVERNORS
                STATE WORKFORCE LIAISONS
                STATE AND LOCAL WORKFORCE BOARD EXECUTIVES

FROM:           BRENT PARTON
                Principal Deputy Assistant Secretary

SUBJECT:        Information Technology (IT) Implementation and Support Funding for Senior
                Community Service Employment Program (SCSEP) State and Territorial
                Grantees for Program Year (PY) 2023

1. Purpose. To announce the availability of $9.5 million to assist SCSEP state and territory
   grantees with IT implementation and support costs related to the Department of Labor
   transition and implementation of the new Grantee Performance Management System
   (GPMS) case management tool. These grants will be funded through SCSEP recaptured
   funds.

2. Action Requested. To apply for PY 2023 IT Implementation and Support Grant funds,
   SCSEP grantees must follow the instructions in this TEGL and submit all documents by
   March 26, 2024.

3. Summary and Background.

   a. Summary – The Employment and Training Administration (ETA) went live with GPMS
      July 1, 2022, creating a new case management tool to modernize service delivery and
      data validation for the SCSEP program. ETA anticipates, however, that SCSEP State and
      Territorial Grantees may still face additional administrative and program costs to
      implement this system going forward. To help State and Territorial Grantees cover these
      implementation and support costs, ETA awarded an initial round of limited funding in
      June 2023, and is now making available one additional round of funding, authorized
      under Section 517(c) of the Older Americans Act (OAA) (42 U.S.C. 3056o(c)) and the
      Further Consolidated Appropriations Act, 2020 (P.L. 116-94). The grant period of
      performance will be 12 months, with an anticipated start date of July 1, 2024-June 30,
      2025; however, ETA encourages grantees to spend these funds earlier in the period of
      performance, since such investments may expedite the success of a grantee’s transition to
      GPMS. ETA will award all IT Implementation and Support Grants by June 30, 2024.

   RESCISSIONS                                             EXPIRATION DATE
   None                                                    Continuing

   b. Background – Section 517(c) of the Older Americans Act (OAA) provides that “…the
      Secretary [of Labor] may recapture any unexpended funds for the program year, and re-
      obligate such funds within the 2 succeeding program years for — (1) incentive grants to
      entities that are State grantees or national grantees under section 502(b); (2) technical
      assistance; or (3) grants or contracts for any other activity under this title.” Additionally,
      the Further Consolidated Appropriations Act, 2020 (P.L. 116-94) provides that SCSEP
      funds appropriated in that year “may be recaptured and reobligated in accordance with
      section 517(c) of the OAA.” In accordance with OAA section 517(c)(3), ETA is making
      a portion of the PY 2020 recaptured funds available for obligation during PY 2023
      exclusively for State and Territorial Grants (and not National Grants) that will cover the
      IT-related costs explained in this TEGL.

4. SCSEP Information Technology Implementation and Support Funding Opportunity.

   a. Eligibility – Eligible applicants for this grant opportunity are current PY 2023 SCSEP
      State and Territorial Grantees (and not National Grantees).

   b. Grant Activities – SCSEP State and Territorial Grant recipients, exclusively, may use this
      funding for:
      1) additional personnel;
      2) technology-related supplies;
      3) technology-related equipment;
      4) contractual costs related to IT and data support; and/or
      5) other costs (which must be allowable under SCSEP regulations and 2 CFR 200) related
      to transitioning to and implementing the new GPMS case management system.

   c. Availability of Funds and Application Review and Award – The Department expects to
      have available approximately $9.5 million of recaptured federal SCSEP funding. The
      Department intends to re-obligate this funding exclusively amongst SCSEP State and
      Territorial Grantees (excluding National SCSEP Grantees), pending their interest and
      submission of applications meeting the requirements of this TEGL. Only SCSEP State
      and Territorial Grantees are eligible; and ETA encourages these grantees to apply and to
      ask for the maximum amount necessary to fully implement the model. SCSEP State and
      Territorial Grantees must submit a justification for the funding request based upon their
      need for the funds. However, when determining this need, eligible SCSEP State and
      Territorial applicants must consider the size and scope of the previous SCSEP base
      award. As a baseline point of reference, we consider a request of 1 – 2 percent of the PY
      2023 federal grant award (with proper justification) as likely appropriate for most, if not
      all, recipients. However, we recognize new systems create certain fixed costs, so for
      smaller SCSEP awards, we will award no less than $150,000, regardless of how much the
      amount exceeds the general target of 1 – 2 percent.

      Final award amounts are subject to the availability of funds. If the cumulative funding
      requested by all applicants exceeds the amount of funds available, all grant awards will
      be reduced proportionately. Conversely, if the cumulative requests are lower than the

   total available amount or if additional funds become available, grant awards may be
   increased proportionately. If ETA does not receive responsive applications, it may
   request applicants, whose applications were deemed non-responsive, to resubmit a
   revised application for reconsideration, depending on the availability of funding. The
   Department may negotiate funding levels and program elements. Selected awardees will
   receive special conditions of award requiring the revision of the SF-424 and budget
   documents should there be discrepancies between funding requests and actual award
   amounts.

   To receive this implementation funding, SCSEP State and Territorial applicants must
   meet all requirements described in this TEGL and submit a responsive application that
   addresses the grant application components outlined in this document, as well as in
   Attachments I and II. If an applicant omits any of the documents, or substantially fails to
   address the requirements of one or more of such documents, ETA will deem their
   application nonresponsive and ineligible for funding consideration. ETA encourages
   applicants to submit quality final applications before the deadline. If an applicant submits
   multiple versions of an application, ETA will consider the latest submitted application to
   be the official submission.

d. Grant Application Requirements – To achieve greater efficiency, and as part of ETA’s
   ongoing effort to streamline the grant award process, grantees must submit the following
   items through Grants.gov:
   1) An electronically signed copy of an SF-424 - Application for Federal Assistance
       (OMB Control No. 4040-0004).
   2) An SF-424A - Budget Information Form – Non-Construction Programs (OMB
       Control No. 4040-0006).
   3) A Budget Narrative that fully explains the projected costs reflected in each line item
       of the SF-424A (see Attachment I for instructions).
   4) A Project Narrative (see Attachment 2 for instructions).

e. Grants.gov Submission Process – Applicants must submit the application package
   through Grants.gov. Applicants who need to register with Grants.gov may do so at the
   following hyperlink: https://www.grants.gov/web/grants/applicants/organization-
   registration.html. Registration is a one-time process; applicants with a Grants.gov
   account do not need to register again. To submit the required application package,
   applicants must:

   1)   Select the Search Grants tab on the Grants.gov homepage.
   2)   Under the section, Basic Search Criteria, enter the Funding Opportunity Number:
        ETA-TBD.
   3)   Select the link to the applicable Opportunity Number provided in the search results.
   4)   Select the Package tab.
   5)   Under the Actions column, select Apply.

   An electronically submitted SF-424 through Grants.gov constitutes the official signed
   document and must reflect the total amount requested in item #18, Estimated Funding.

     Item #11 must include the Catalog of Federal Domestic Assistance Number, 17.235. ETA
     encourages application submission as soon as possible; however, applications must be
     received by 11:59 PM EST on March 26, 2024. This submission process may, at times, be
     complicated and time-consuming. As such, the Department strongly encourages
     applicants to initiate the process as soon as possible to allow time to resolve unanticipated
     technical problems.

     Applicants must supply a Unique Entity Identifier (UEI) on the SF-424. If your entity is
     registered with the System for Award Management (SAM) SAM.gov, your UEI has
     already been assigned and is viewable under your entity record. Organizations not
     registered with SAM.gov can obtain more information about a UEI at www.sam.gov.
     Before submitting, applicants must also ensure their registration with SAM.gov.
     Applicants may find instructions for registering with SAM at https://www.sam.gov. An
     awardee must always maintain an active SAM registration with current information
     during which it has an active Federal award or an application under consideration. To
     remain registered in the SAM database after the initial registration, entities must review
     and update the registration at least every 12 months from the date of initial registration.
     Failure to register with SAM and maintain an active account will result in Grants.gov
     rejecting the application submission.

     For technical issues encountered during application submission, applicants may call 800-
     518-4726 or 606-545-5035 to speak to a Customer Support Representative or email
     grants.gov/support The Contact Center is open 24 hours a day, seven days a week, but
     closes on federal holidays.

f.   Administrative and Program Costs – Subpart H of the SCSEP regulations define the
     functions and activities that constitute administrative and program costs at 20 CFR
     641.856 and at 20 CFR 641.864, respectively. Administrative costs include both
     personnel and non-personnel costs and both direct and indirect costs. Also, note that
     section 641.859 provides special rules governing the classification of SCSEP
     administrative and program costs. Given that this additional funding is separate from the
     SCSEP base funds, proposed expenditures for this grant operate on a PY basis, from July
     1 through the following June 30 and are not required to meet the 13.5 percent
     administrative cost limits as required by formula provided in Section 506 of the Older
     Americans Act of 1965 (OAA), as amended, 42 USC §3056d.

g. Other Award Considerations – At its discretion, ETA intends to fund applicants who
   adequately demonstrate eligibility and meet the application requirements set out in this
   TEGL. ETA may elect to award a grant with or without discussions with the applicant.
   Should a grant be awarded without discussions, the award will be based on the
   applicant’s signature on the SF-424, including an electronic signature, which constitutes a
   binding offer by the applicant.

     NOTE: The Department will determine if the applicant had any restriction on spending
     for any ETA grant due to adverse monitoring findings within the past three years.

   Depending on the severity of the findings, the Grant Officer may elect to not provide the
   applicant a grant award or to impose conditions on the award.

   All applications deemed to be complete and responsive by the Grant Officer will go
   through a risk review process. Before making an award, ETA will review information
   available through any OMB-designated repository of government-wide eligibility
   qualification or federal integrity information, such as the Federal Awardee Performance
   and Integrity Information System (FAPIIS), and “Do Not Pay.” Additionally, ETA will
   comply with the requirements of 2 CFR Part 180 (Government-wide Debarment and
   Suspension (Non-Procurement)). This risk evaluation may incorporate results of the
   evaluation of the applicant’s eligibility (application screening), or the quality of its
   application (technical review). If ETA determines that an entity is responsible and an
   award will be made, special conditions that correspond to the degree of risk assessed may
   be applied to the award. Risk related criteria evaluated include:

   •   Financial stability.
   •   Quality of management systems and ability to meet the management standards
       prescribed in the Uniform Grant Guidance.
   •   History of performance. The Applicant’s record in managing awards, cooperative
       agreements, or procurement awards, if it is a prior recipient of such Federal
       awards, including timeliness of compliance with applicable reporting
       requirements, and if available, the extent to which any previously awarded
       amounts will be expended prior to future awards.
   •   Reports and findings from audits performed under Sub-part F – Audit
       Requirements of the Uniform Grant Guidance (2 CFR 200.500 –2 CFR 200.520)
       or the reports and findings of any other available audits and monitoring reports
       containing finds, issues of non-compliance, or questioned costs; and
   •   The applicant’s ability to effectively implement statutory, regulatory, or other
       requirements imposed on recipients.
   The selection of an organization as a recipient does not constitute approval of the grant
   application as submitted. Before the actual grant is awarded, the Department may
   negotiate with an applicant regarding such items as program components, staffing and
   funding levels, and administrative systems in place to support grant implementation. If
   the negotiations do not result in a mutually acceptable submission, the Grant Officer
   reserves the right to terminate the negotiations and decline to fund the application. The
   Department reserves the right to not fund any application related to this TEGL.

h. Grantee Performance Reporting Requirements
   1) Financial Reports. All ETA award recipients are required to report financial data on
      the ETA-9130 Financial Report. ETA-9130 reports are due no later than 45 calendar
      days after the end of each specified reporting quarter. Reporting quarter 6 end dates
      are March 31, June 30, September 30, and December 31. A final 9130 for the last
      quarter of the period of performance must be submitted no later than 120 calendar
      days after the quarter ends. See 2 CFR 200.344. Note: On April 3, 2023, ETA replaced

      its legacy E-Grants Grantee Reporting System (GRS) by transitioning to the Payment
      Management System (PMS) for grant recipient submission of the quarterly ETA-9130
      financial reports. PMS is operated by the U.S. Department of Health and Human
      Services (HHS). Please see Training and Employment Notice No. 16-22 for additional
      information.

   2) Performance Reports. Since these funds are specifically for IT implementation and
      support, ETA is not asking for separate additional performance reports on employment
      outcomes of participants. However, grantees that receive these funds should provide
      status updates on activities that the funds support in their quarterly narrative reports,
      both how these funds are used and the status of any larger activity to which the funds
      are contributing. Grantees should continue to submit program performance reports for
      their base grants.

i. Paperwork Reduction Act (PRA) Statement - The Department notes that a federal
   agency may not conduct or sponsor a collection of information, nor is the public required
   to respond to a collection of information, unless the Office of Management and Budget
   (OMB), under the PRA, approves it, and it displays a currently valid OMB Control
   Number (44 U.S.C. 3507). SCSEP Performance Data Collection Approval (OMB No.
   1205-0040) (expiration date November 30, 2024).

   Also, notwithstanding any other provision of law, no person shall be subject to penalty
   for failing to comply with a collection of information if the collection of information does
   not display a currently valid OMB Control Number (44 U.S.C. 3512). According to the
   Paperwork Reduction Act of 1995, no persons are required to respond to a collection of
   information unless such collection displays a valid OMB control number. Public
   reporting burden for this collection of information is estimated to average 20 hours per
   response, including time for reviewing instructions, searching existing data sources,
   gathering, and maintaining the data needed, and completing and reviewing the collection
   of information.

   Send comments about the burden estimated or any other aspect of this collection of
   information, including suggestions for reducing this burden, to the U.S. Department of
   Labor, to the attention of the Departmental Clearance Officer, 200 Constitution Avenue,
   NW, Room N-1301, Washington, D.C. 20210. Comments may also be emailed to:
   [email protected].

   Please do not return your grant application to this address. Send only comments about the
   burden caused by the collection of information to this address. Send your grant
   application to the sponsoring agency as specified earlier in this announcement. The
   information being collected through this Training and Employment Guidance Letter is
   for the purpose of awarding a grant. This information is required to be considered for this
   grant.

j. Notice of Grant Award – ETA will issue a notice of grant award with new grant numbers
   and obligation amounts.

5. Inquiries. Questions regarding this guidance should be directed to Grant Specialist
   [email protected].

6. References.
      • Older Americans Act (42 USC 3056, et seq.), as amended through Public Law
         116-131 (March 25, 2020);
      • Further Consolidated Appropriations Act, 2020 (P.L. 116-94) (September 30, 2020)
      • Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES Act), Pub. L.
         116-136 (March 27, 2020);
      • Workforce Innovation and Opportunity Act (WIOA), Pub. L. 113-128, Sec. 121,
         Funding of One-Stop Infrastructure;
      • Paperwork Reduction Act of 1995, Pub. L. 104-13 (May 22, 1995)
      • OMB Uniform Administrative Requirements, Cost Principles, and Audit
         Requirements for Federal Awards; published at 2 CFR Part 200;
      • TEGL 17-20, Senior Community Services Employment Program -Updated Guidance
         on Priority of Service, Durational Limits, and State Plan Submissions (April 15,
         2021);
      • TEGL 17-16, Infrastructure Funding of the One-Stop Delivery System (January 18,
         2017); and
      • SCSEP Performance Data Collection (OMB No. 1205-0040, expiration date
         November 30, 2024).

7. Attachment(s).
      • Attachment I: Budget Narrative Instructions
      • Attachment II: Program Narrative Instruction

                                                                                Attachment I
 Program Year (PY) 2023 Information Technology (IT) Implementation and
                       Support Funding for Senior
                Community Service Employment Program
                                (SCSEP)
                      Budget Narrative Instructions

   Applicants must provide a detailed Budget Narrative that fully explains the costs
   identified on each line item of the SF-424A Budget Information Form. See the required
   information and related guidance below.
a. Personnel: List all staff positions working on the proposed grant project by title (both
   current and proposed), including the roles and responsibilities. For each position give
   the annual salary, the percentage of time devoted to the project, and the amount of
   each position’s salary funded by the grant. This line item does include personnel hired by
   the sub-grantee to provide data entry, migration, and management of the case
   management tool.
b. Fringe Benefits: Provide a breakdown of the amounts and percentages that comprise
   fringe benefit costs such as health insurance, FICA, retirement, etc.
c. Travel: For grant staff only, specify the purpose, number of staff traveling, mileage, per
   diem, estimated number of in-state and out-of-state trips, and other costs for each type
   of travel.
d. Equipment: Identify each item of equipment you expect to purchase that has an
   estimated acquisition cost of $5,000 or more per unit (or if your capitalization level is
   less than $5,000, use your capitalization level) and a useful lifetime of more than one
   year (see 2 CFR 200.1 for the definition of Equipment). List the item, quantity, and the
   unit cost per item. Items with a unit cost of less than $5,000 are supplies, not
   “equipment.” Additionally, please note the following:
       a. Information technology systems are defined as computing devices, ancillary
          equipment, software, firmware, and similar procedures, services (including
          support services), and related resources. [2 CFR 200.1]
       b. Computing devices are defined as machines used to acquire, store, analyze,
          process, and publish data and other information electronically, including
          accessories (or ‘peripherals’) for printing, transmitting, and receiving, or storing
          electronic information. [2 CFR 200.1]

        c. While the definition of information technology systems includes computing
           devices, such devices with a per-unit acquisition cost of less than the
           capitalization level established by the non-Federal entity for financial statement
           purposes, or $5,000 are classified as supplies, not equipment.
        d. Procurement requirements for grant recipients are contained in the Uniform
           Administrative Requirements, Cost Principles, and Audit Requirements for
           Federal I-1 Awards (Uniform Guidance) at 2 CFR 200.317 - .326. ETA does not
           approve or disapprove the procurement method used by the recipient, provided
           it is consistent with the requirements in the Uniform Guidance (2 CFR 200.317-
           .326). By their signature on the Grant Agreement, the recipient has accepted
           these conditions and assured their compliance with appropriate procurement
           requirements.
        e. All equipment purchases require prior approval by a Grant Officer. Applicants
           should provide accurate estimates for proposed equipment expenditures in the
           application for this grant; however, the initial award of the IT Implementation
           and Support Grants does not constitute prior approval of the identified
           equipment costs. Selected awardees for these grants must submit a subsequent
           modification seeking prior approval, which must include additional
           documentation for the Grant Officer to determine allowability of the proposed
           costs. 2 CFR 2900.16 requires this request to “be submitted not less than 30 days
           before the requested action is to occur.” Selected awardees must consult their
           Federal Project Officer regarding the information required for the equipment
           modification request.
e. Supplies: Identify in the detailed budget the projected cost of supplies, per category
   (e.g., general office supplies, desks/chairs, laptops/printers, other specialty items).
   Except for general office supplies, list the item, quantity, and the unit cost per item.
   Supplies include all tangible personal property other than “equipment.” (See 2 CFR 200.1
   for the definition of Supplies.)
f.   Contractual: Under the Contractual line item, delineate contracts and subawards
     separately. Contracts are defined according to 2 CFR 200.1 as a legal instrument by
     which a non-federal entity purchases property or services needed to carry out the
     project or program under a federal award. A subaward, also defined under 2 CFR 200.1,
     means an award provided by a pass-through entity to a subrecipient for the subrecipient
     to carry out part of a federal award received by the pass-through entity. It does not
     include payments to a contractor or payments to an individual that is a beneficiary of a
     federal program. For each proposed contract and subaward, specify the purpose and
     activities to be provided, and the estimated cost.

g. Construction: Construction costs are not allowed, and this line must be left as zero.
   Minor alterations to adjust an existing space for grant activities (such as altering a space
   to accommodate IT equipment) may be allowable. We do not consider this as
   construction, and you must show the costs on other appropriate lines such as
   Contractual.
h. Other: Provide clear and specific detail, including costs, for each item so that the Grant
   Officer may determine whether the costs are necessary, reasonable, and allocable. List
   items, such as stipends or incentives, not covered elsewhere.
i.   Indirect Costs: If you include an amount for indirect costs (through a Negotiated Indirect
     Cost Rate Agreement or De Minimis) on the SF-424A budget form, then include one of
     the following: I-2
        a. If you have a Negotiated Indirect Cost Rate Agreement (NICRA), provide an
           explanation of how the indirect costs are calculated. This explanation should
           include which portion of each line item, along with the associated costs, are
           included in your cost allocation base. Also, provide a current version of the
           NICRA.
or
        b. If you intend to claim indirect costs using the 10 percent de minimis rate, please
           confirm that your organization meets the requirements as described in 2 CFR
           200.414(f). Clearly state that your organization does not have a current
           negotiated (including provisional) rate, and is not one described in 2 CFR 200,
           Appendix VII(D)(1)(b).
Applicants choosing to claim indirect costs using the de minimis rate must use Modified
Total Direct Costs (see 2 CFR 200.1 below for definition) as their cost allocation base. Provide
an explanation of which portion of each line item, along with the associated costs, are
included in your cost allocation base. Note that there are various items not included in the
calculation of Modified Total Direct Costs. See the definitions below to assist you in your
calculation.
Modified Total Direct Cost (MTDC) [2 CFR 200.1] means all direct salaries and wages,
applicable fringe benefits, materials and supplies, services, travel, and subawards and
subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the
period of performance of the subawards and subcontracts under the award). MTDC
excludes equipment, capital expenditures, charges for patient care, rental costs, tuition
remission, scholarships and fellowships, participant support costs and the portion of each
subaward and subcontract more than $25,000. Other items may only be excluded when
necessary to avoid a serious inequity in the distribution of indirect costs, and with the

approval of the cognizant agency for indirect costs. Participant support costs are defined
below.
Participant Support Costs [2 CFR 200.1] mean direct costs for items such as stipends or
subsistence allowances, travel allowances, and registration fees paid to or on behalf of
participants or trainees (but not employees) in connection with conferences or training
projects.
The following link contains information regarding the negotiation of Indirect Cost Rates at
DOL: indirect cost rates.
Note that the SF-424, SF-424A, and Budget Narrative must include the entire federal grant
amount requested. Do not show leveraged resources on the SF-424 and SF-424A. You
should describe leveraged resources in the Budget Narrative. Applicants should list the same
requested federal grant amount on the SF-424, SF-424A, and Budget Narrative. If minor
inconsistencies are found between the budget amounts specified on the SF-424, SF-424A,
and the Budget Narrative, DOL will consider the SF-424 the official funding amount
requested.

                                                                                Attachment II
    Program Year (PY) 2023 Information Technology (IT) Implementation and
  Support Funding for Senior Community Service Employment Program (SCSEP)

                             Program Narrative Instructions
All grantees must provide a program narrative that concisely covers the areas below. Justify the
request for IT implementation and support funds by providing evidence of the following. Ensure
that these descriptions are consistent with the information in your Budget Narrative. Include:
   a. A detailed description of the activities planned on how the funds will be spent directly
      on the Grantee Performance Management System (GPMS) transition functions.
   b. A description of how the funds will improve the effectiveness of the transition to GPMS
      related to hiring, training, data migration, data validation, hardware or software
      technologies and equipment to implement the new system most effectively.
   c. Information related to the temporary hiring or contracting of personnel needed to
      facilitate the data migration, data connectivity, and/or other tasks related to GPMS
      implementation.
   d. Justification for the purchase of supplies such as computers or other hardware to
      upgrade outdated equipment incompatible with the new case management tool and
      proportionate to the size of the grantee program.
   e. Justification for the purchase of any equipment or ancillary supplies needed by the
      grantee to fully implement the GPMS case management tool, and in accordance with
      the statutes and laws governing SCSEP grants.
   f. A schedule to monitor and audit grant funds along with assurances funding will be spent
      only on administrative and program costs related to GPMS transition and
      implementation.
   g. A financial status report is required at the time all funds have been expended or the
      grant period has expired. On the financial status report grantees must include any
      qualitative outcomes not directly supported by final expenditures.