ETA-9130 training expenditure reporting and payment system transition

CLASSIFICATION
      EMPLOYMENT AND TRAINING ADMINISTRATION                  Financial Reporting
                  ADVISORY SYSTEM                             CORRESPONDENCE SYMBOL
             U.S. DEPARTMENT OF LABOR                         OGM
                Washington, D.C. 20210                        DATE
                                                              May 12, 2023

ADVISORY:         TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 16-22

TO:               STATE WORKFORCE AGENCIES
                  STATE WORKFORCE ADMINISTRATORS
                  STATE WORKFORCE LIAISONS
                  STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS
                  ALL DIRECT ETA GRANT RECIPIENTS

FROM:             BRENT PARTON
                  Acting Assistant Secretary

SUBJECT:          Revised ETA-9130 Financial Report Instructions and Additional Guidance

1. Purpose. This guidance informs the workforce system of clarifications made to the
   instructions for the Training Expenditures line item on some of the Employment and Training
   Administration’s (ETA) financial reports (ETA-9130) and shares information regarding the
   transition of ETA’s quarterly financial reporting to the U.S. Health and Human Services
   Payment Management System (PMS).

2. Action Requested. Please disseminate this guidance to all staff directly or indirectly responsible
   for financial management and financial reporting for ETA grant awards and cooperative
   agreements. ETA grant recipients should submit their cumulative financial information using the
   appropriate ETA-9130 financial report and the updated instructions immediately. Beginning
   with the reporting period ending 3/31/2023, grant recipients will submit their quarterly ETA-
   9130 financial reports in PMS.

3. Summary and Background.

      a. Summary – This guidance provides clarification on the instructions for the Training
         Expenditures line item for certain ETA-9130 financial reports for the continual tracking
         and reporting of training expenditures to support Workforce Innovation and
         Opportunity Act (WIOA) legislative requirements. It also informs grant recipients of
         upcoming changes in the ETA-9130 financial reporting process.

      b. Background – Every grant awarded by ETA requires accurate quarterly reporting as a
         part of sound financial and management responsibilities. This reporting supports the
         Department of Labor’s (DOL) ability to measure fund utilization for performance
         accountability and assess compliance with statutory expenditure requirements. This
         information also helps measure successful outcomes for participants, ensures sound

   RESCISSIONS                                               EXPIRATION DATE
   TEGL 20-19                                                Continuing

     service delivery and reporting practices and determines whether the federal funds achieved
     maximum benefit.

     ETA requires all award recipients to report their financial data on an accrual basis each
     quarter using the ETA-9130 financial reports (2 CFR 2900.14). ETA made
     modifications to the instructions for the Training Expenditures line item for certain ETA-
     9130 financial reports available for public comment, as required by the Paperwork
     Reduction Act, in a 60-day Federal Register Notice published at 87 FR 25304 on April
     28, 2022, and through a 30-day Federal Register Notice published at 87 FR 58376 on
     September 26, 2022. On January 17, 2023, the Office of Management and Budget
     (OMB) approved these modifications to the instructions as part of the extension of
     the use of the ETA-9130 financial reports (OMB Control No. 1205-0461) through
     January 31, 2025. The approved forms and instructions are available at:
     https://www.dol.gov/agencies/eta/grants/management/reporting.

     The use of the ETA-9130 financial reporting forms is required for all existing and new
     grant awards. Grant recipients must report cumulative figures on these forms, starting
     from grant inception to the end of the reporting period.

     This update also clarifies the definition of the Training Expenditures line item for those
     ETA-9130 financial reports that contain that line item. For ETA-9130 financial reports
     with the Training Expenditures line item, the requirement to track and report on such
     expenditures dates back to at least Program Year (PY) 2020, and in some cases further.
     Training Expenditures have been required to be reported on the ETA-9130 financial
     reports for the following programs effective the quarter ending:

        6/30/2020 – WIOA Adult, WIOA Dislocated Worker and WIOA Youth
        9/30/2016 – National Dislocated Worker Grants and Trade Adjustment Assistance
        6/30/2013 – Indian and Native American Programs

4. Revised ETA-9130 Financial Reporting Guidance.

    a. WIOA Outlying Areas.

       Beginning with the reporting period ending 6/30/2023, outlying areas that have requested
       and been approved to use a consolidated grant application for WIOA should use the
       ETA-9130 Basic financial reporting form for financial reporting.

    b. Training Expenditures Line Item Instructions.

       As mentioned above, the Training Expenditures line item has been a part of the financial
       reporting requirements listed below going back to at least the PY 2020 ETA-9130
       financial reports, and, in some cases, longer. This means that any ETA-9130 financial
       reports submitted for the programs listed below must include expenditures on training in
       this line item. Some states that have failed to meet this requirement have expressed that
       clearer definitions are needed to help them report. Therefore, in this latest OMB

approved renewal of the ETA-9130 financial report series, ETA clarified the instructions
for the Training Expenditures line item for the following ETA-9130 financial reports:

   •   ETA-9130 (A) – Statewide Youth
   •   ETA-9130 (B) – Local Youth

 Training     Enter the cumulative amount of expenditures for training services provided to
 Expenditures Youth program participants.

               This line item should consider all costs for training, including, but not limited
               to tuition, fees, books, tools, transportation, other supportive services to
               enable participation in training, etc., as applicable. All forms of training, as
               defined in guidance, must be accounted for, with the exception of Youth on-
               the-job training (OJT), as OJT is considered a work experience and not
               considered training in the WIOA Youth program. In addition, please
               note that entrepreneurial skills training, job readiness training, and Adult
               Basic Education/English as a Second Language are not considered
               training services for the WIOA Youth program and expenditures
               associated with such services must not be included. Pre-apprenticeship is
               reported as both work experience and training; therefore, costs associated with
               the training portion of pre-apprenticeship should be included in training
               expenditures.

               This line item should represent the total accrued training activities
               expenditures for this Youth Grant and is included in the amount reported in
               10e (Federal Share of Expenditures).

   •   ETA-9130 (C) – Statewide Adult
   •   ETA-9130 (D) – Local Adult

 Training     Enter the cumulative amount of expenditures for training services provided to
 Expenditures Adult program participants.

               This line item should consider all costs for training, including, but not limited to
               tuition, fees, books, tools, transportation, other supportive services to enable
               participation in training, etc., as applicable. All forms of training, as defined in
               guidance, must be accounted for.
               This line item should represent the total accrued training activities expenditures
               for this Adult Grant and is included in the amount reported in 10e (Federal
               Share of Expenditures).

  •   ETA-9130 (E) – Statewide Dislocated Worker
  •   ETA-9130 (F) – Local Dislocated Worker

Training     Enter the cumulative amount of expenditures for training services provided to
Expenditures Dislocated Worker program participants.

              This line item should consider all costs for training, including, but not limited to
              tuition, fees, books, tools, transportation, other supportive services to enable
              participation in training, etc., as applicable. All forms of training, as defined in
              guidance, must be accounted for.

              This line item should represent the total accrued training activities expenditures
              for this Dislocated Worker Grant and is included in the amount reported in 10e
              (Federal Share of Expenditures).

  •   ETA-9130 (G) – National Dislocated Worker Grants

Training     Enter the cumulative amount of expenditures for training services provided to
Expenditures National Dislocated Worker Grant program participants.

              This line item should consider all costs for training, including, but not limited to
              tuition, fees, books, tools, transportation, other supportive services to enable
              participation in training, etc., as applicable. All forms of training, as defined in
              guidance, must be accounted for.

              This line item should represent the total accrued training activities expenditures
              for this National Dislocated Worker Grant and is included in the amount
              reported in 10e (Federal Share of Expenditures).

  •   ETA-9130 (L) – Indian and Native American (INA) Program

Training     Enter the cumulative amount of expenditures for training services provided to
Expenditures INA program participants.

              This line item should consider all costs for training, including, but not limited to
              tuition, fees, books, tools, transportation, other supportive services to enable
              participation in training, etc., as applicable. All forms of training, as defined in
              guidance, must be accounted for.

              This line item should represent the total accrued training activities expenditures
              for this INA grant and is included in the amount reported in 10e (Federal Share
              of Expenditures).

      •   ETA-9130 (M) – Trade Adjustment Assistance Program

    Training     Enter the cumulative amount of expenditures for training services provided to
    Expenditures Trade Adjustment Assistance program participants.

                  This line item should consider all costs for training, including, but not limited
                  to tuition, fees, books, tools, transportation, etc., as applicable. All forms of
                  training, as defined in guidance, must be accounted for.

                  This line item should represent the total accrued training activities expenditures
                  for all Trade Adjustment Assistance training services, whether the funds were
                  expended at the State or local level and is included in the amount reported in
                  10e (Federal Share of Expenditures).

c. Payment Management System (PMS) – Financial Reporting System.

   ETA implemented GrantSolutions (GS) to replace its legacy grant processing system, E-
   Grants, on February 6, 2023. As a part of this implementation, on April 3, 2023, ETA
   replaced the E-Grants Grant Reporting System with the new PMS Financial
   Reporting System for grant recipient submission of the quarterly ETA-9130
   financial reports. Beginning with the reporting period for the quarter ending 3/31/2023,
   grant recipients will submit their ETA-9130 financial reports in PMS. Training and
   Employment Notice No. 16-22 provides additional guidance and information on how to
   access and use the PMS Financial Reporting System for the submission of ETA-9130
   quarterly financial reports: https://www.dol.gov/agencies/eta/advisories/ten-16-22.
d. Reporting Guidance.

   General
   Recipients must submit an ETA-9130 financial report for each subaccount listed
   on their Notice of Award (NOA) document. All reported financial data must be
   based on the accrual basis of accounting and be cumulative by fiscal year of
   appropriation through the entire period of performance (POP). Recipients are not
   required to convert their accounting system if it is not on an accrual basis. In
   instances where accounting systems do not have the capability of reporting on an
   accrual basis, recipients must develop and report accrual information through best
   estimates based on an analysis of the documentation available.

   Report Submission Process

   Grant Recipient Data Entry
   The secondary contact designated by the recipient organization is responsible for
   entering the required ETA-9130 financial data into PMS. Most often, the
   secondary contact is a designated finance/reporting person with a limited role in
   program/grant implementation. In these instances, it may be necessary for the

secondary contact to collaborate with staff responsible for program/grant
implementation (and/or reporting) to facilitate complete and accurate financial
reporting. This applies particularly when recipients utilize separate systems for
financial and grant activity tracking, or when recipients’ accounting systems
operate on a cash basis.

Data Certification
The primary contact is responsible for certifying the accuracy of the financial data
the secondary contact enters into PMS. The primary contact serves a different
role than the secondary contact and hence the certification authority should be
held by a different individual than the individual that holds the secondary contact
role.

Data Approval
ETA staff will review and either approve or reject the recipient’s ETA-9130
financial report within 10 business days after report certification by the primary
contact. If ETA’s review results in the rejection of the ETA-9130 submission, the
ETA reviewer will include the reason for the rejection in the appropriate field. A
notification will be sent to the recipient of the rejection/reason for the rejection.
The recipient will then be responsible for revising the ETA-9130 submission to
address the concern(s), re-submitting, and re-certifying the revised ETA-9130
financial report.

Revisions to Prior Reports
A recipient cannot revise a previously submitted ETA-9130 financial report once
the subsequent quarter’s report is generated in PMS. Adjustments on prior locked
reports may occur only in limited circumstances and with approval from ETA.
Requests for adjustments on prior locked reports should be submitted to the
appropriate ETA regional office. ETA-9130 financial reports are cumulative, so
recipients should make any minor adjustments on the next submitted report with
an explanation of the change in Section 12, Remarks.

Report Submission Due Dates

Initial ETA-9130 – The date the Grant Officer signs the NOA determines the due
date of the initial ETA-9130 financial report, as shown in the following chart.
Please note, this is a change from prior years, as effective dates are no longer
recognized by the GS system.

                             Initial ETA-9130        Initial ETA-9130
  Date NOA Signed
                             Quarter End Date            Due Date
       3/28/2023                 3/31/2023               5/15/2023
        7/1/2023                 9/30/2023              11/15/2023
      12/28/2023                12/31/2023               2/15/2024

Quarterly ETA-9130 Financial Report Due Dates – ETA-9130 financial reports are due
not later than 45 calendar days after the end of each quarter, as shown in the following
chart:

            Quarter End Date                Quarterly ETA-9130 Due Date
                March 31                               May 15
                June 30                               August 15
              September 30                          November 15
              December 31                            February 15

The deadline to submit ETA-9130 financial reports does not change in instances
when the reporting due date falls on a weekend or holiday. Recipients can submit
reports at any time in advance of the due date.

End of Grant Reporting – Once a grant has reached its POP end date, the recipient will
submit its final ETA-9130 financial report.

    1. For grants awarded prior to November 12, 2020, the final ETA-9130 financial
      report must be submitted no later than 90 calendar days after the POP end date.

    2. For grants awarded on or after November 12, 2020, the final ETA-9130 financial
      report must be submitted no later than 120 calendar days after the POP end date.

The following chart provides examples of due dates for the final ETA-9130 financial
report:
                                                  Final ETA-       Final ETA-
                                  All Funds
                                                     9130             9130
                  Grant POP      Expended or
                                                  Quarter End      Report Due
                                 POP Expired
                                                     Date             Date
   Awarded
     Before       7/17/2020 –
                                   9/30/2023        9/30/2023       12/29/2023
  11/12/2020       9/30/2023
   (90 days)
 Awarded On
    or After      12/1/2020 –
                                   9/30/2023        9/30/2023       1/28/2024
  11/12/2020       9/30/2023
  (120 Days)

Note: A Closeout ETA-9130 financial report is no longer required. The final ETA-
9130 financial report, which will be approved by the closeout Grant Officer, will be
used for the purposes of conducting grant closeout. Adjustments to the final ETA-
9130 financial report can be made during the closeout process, if necessary. A
closeout package will be emailed to the recipient within seven days of the POP end
date. See Training and Employment Guidance Letter No. 12-22 for additional
information: https://www.dol.gov/agencies/eta/advisories/tegl-12-22.

5. Inquiries. Please direct any inquiries as follows:

    a. Questions on this Guidance – please contact your assigned Federal Project Officer (FPO)
       or the appropriate regional office.

    b. Assistance with Completing the ETA-9130 Financial Reports – please contact your
       assigned regional representative or the appropriate regional office.

    c. Questions on the Final ETA-9130 Financial Report – please consult with the Closeout
       Specialist assigned to the award and copy your assigned regional representative.

    d. Technical Assistance with the Online Reporting System – please contact the PMS
       Helpdesk at: [email protected] and copy your assigned FPO. Submit an online
       ticket: https://gditshared.servicenowservices.com/hhs_pms.

        To facilitate an expeditious response, please include the following information in your
        request:
           • Grant recipient name
           • Grant number
           • Quarter end date of the report for which technical assistance is needed
           • Contact name and telephone number (in the event a telephone call is needed)
           • Description of the issue

    e. Grant Closeout Information – please visit:
       https://www.dol.gov/agencies/eta/grants/management/closeout

6. References.

    •   Workforce Innovation and Opportunity Act (WIOA) (Pub. L. 113-128) Titles I, III, and
         V, as amended;
    •   2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit
        Requirements for Federal Awards;
    •   Paperwork Reduction Act of 1995 (PRA), codified at 44 U.S.C. §§ 3501–3521;
    •   87 FR 25304, 60-Day Federal Register Notice, ETA Financial Report Form ETA-9130;
    •   87 FR 58376, 30-Day Federal Register Notice, ETA Financial Report Form ETA-9130;
    •   Consolidated Appropriations Act, 2023 (Pub. L. 117-328), Division H, Title I,
        Department of Labor, Employment and Training Administration, Training and
        Employment Services, paragraph (1)(C);
    •   Training and Employment Notice No. 16-22, The Employment and Training
        Administration is Implementing GrantSolutions for Grant Award Processing and the
        Payment Management System for Financial Reporting; and
    •   Training and Employment Guidance Letter No. 12-22, Award Closeout Process for
        Expired Grants and Agreements.

7. Attachment(s). Not Applicable.