YouthBuild orientation allowable costs

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2010/TEGL14-09acc.pdf

CLASSIFICATION
  EMPLOYMENT AND TRAINING ADMINISTRATION             WIA/Youth
              ADVISORY SYSTEM                        CORRESPONDENCE SYMBOL
                                                     OWI-DYS
         U.S. DEPARTMENT OF LABOR
                                                     DATE
            Washington, D.C. 20210                   February 25, 2010



ADVISORY:        TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 14-09

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

FROM:            JANE OATES /s/
                 Assistant Secretary

SUBJECT:         MENTAL TOUGHNESS/ORIENTATION ALLOWABLE COSTS IN A
                 YOUTHBUILD PROGRAM

1. Purpose. To provide clarification on allowable costs associated with Mental
Toughness/Orientation activities under the YouthBuild Program

2. References. Workforce Investment Act of 1998 (WIA) 20-C.F.R. 662.220

3. Background. Many YouthBuild programs conduct “Mental Toughness” or
Orientation activities with prospective youth applicants to assist in the pre-screening
and selection of program participants. Initial intake or informal interviews with
YouthBuild applicants give staff an excellent opportunity to gauge prospective
participants and their readiness for the rigors of the YouthBuild program and to
conduct a preliminary program eligibility screen prior to actually enrolling them in the
program (see DOL’s Eligibility Guidelines). Questions on Mental
Toughness/Orientation activities and allowable cost expenses have arisen from the
YouthBuild system. This guidance is designed to provide clarification on allowable
costs associated with Mental Toughness/Orientation activities which take place prior to
enrollment.

4. Allowable Costs for Mental Toughness/Orientation Activities.

Mental Toughness/Orientation is an allowed YouthBuild program activity which takes
place prior to participant enrollment. However, there are limitations on the types of
activities which are considered allowable costs because potential participants are not
officially enrolled in the YouthBuild program.


 RESCISSIONS                                        EXPIRATION DATE
 None                                               Continuing

When determining actual enrollment for a youth, YouthBuild staff should consider
official enrollment at the point that Mental Toughness/Orientation is completed,
selection of participants has occurred, and the youth have been entered into the
Department of Labor’s (DOL’s) Case Management and Performance information system
with an enrollment date in the YouthBuild program. The Mental
Toughness/Orientation component of a YouthBuild program may not utilize DOL
funds to pay for resources or services such as participation in a ropes course, travel
costs, or speaker fees. In the case where the activities identified above are included in a
Mental Toughness/Orientation program offered by a local YouthBuild program, DOL
suggests leveraging other funds to pay for these activities.

Other examples of services or resources for youth that are not allowable costs during
Mental Toughness/Orientation is the purchase of work boots, bus tokens, tuition and
books, stipends or other supportive services a young person may need. These are not
considered an allowable cost until a youth is officially enrolled in the YouthBuild
program. Costs charged to the DOL grant for these types of services for youth not
formally enrolled in the YouthBuild program through the Case Management and
Performance information system will be disallowed.

DOL funds appropriated for YouthBuild may be expended for some services that are
conducted during Mental Toughness/Orientation prior to enrollment as they constitute
appropriate recruitment and eligibility determination activities, both of which are
allowable costs. These may include the following: background checks, drug tests, staff
time, or assessment tools. YouthBuild staff and administrators should adhere to the
guidelines below when developing activities during the Mental Toughness/Orientation
phase of the program to ensure that costs incurred for such activities are allowable
costs:

1.     Limit Mental Toughness/Orientation or any pre-enrollment activities to a time
       period of no longer than three weeks in length, preferably two weeks.
2.     Do not spend DOL funds on non-enrolled program participants for services such
       as ropes courses, clothing, hotel or camping costs for a retreat, or speaker fees.
3.     Do not spend DOL funds for stipends, wages, or supportive services that can
       only be provided to youth after they are formally enrolled as YouthBuild
       participants in the Case Management and Performance Information System with
       an official enrollment date.
4.     Maintain a record on each youth participating in Mental Toughness/Orientation
       and, if the youth is not chosen as a participant, a note should detail why they
       were not enrolled. Another option is to make a note indicating a referral to
       another employment training program (e.g., One-Stop Career Center or Job
       Corps) or recommending a youth re-apply to the YouthBuild program at another
       time in the future.
5.     Develop a policy that outlines the parameters of the Mental
       Toughness/Orientation activities. This policy should describe the process and
       include information such as the length of time, costs of appropriate funding
       allocations, and expected activities. Guidelines could also clarify the

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      qualifications for potential YouthBuild participants and include specific
      information on what the program deems as appropriate for participant success in
      the YouthBuild program.
6.    Use leveraged funds to pay for costs associated with Mental
      Toughness/Orientation activities that fall outside of this general guidance.

5. Inquiries. YouthBuild grantees should contact their Federal Project Officers if they
have any questions or need clarification about this guidance. Any additional questions
or comments can be addressed to Anne Stom, Division of Youth Services, OWI, at 202-
693-3377 or [email protected].




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