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Trade Adjustment Assistance financial reporting alignment
Summary ETA instructed state agencies how to align Trade Adjustment Assistance participant records with ETA-9130 financial reports. It addressed accrual accounting, expenditure categories, adjustments, payments for workers in multiple programs, and improper payments. The letter aims to make TAA spending and participant cost data consistent across the two reports.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
TEGL No. 18-20
Date issued
April 26, 2021
Status
Active
ETA lists this advisory as active. It prints an expiration date of Continuing and no rescissions.
Status last verified October 24, 2026
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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
CLASSIFICATION
EMPLOYMENT AND TRAINING ADMINISTRATION Trade Adjustment Assistance
ADVISORY SYSTEM CORRESPONDENCE SYMBOL
U.S. DEPARTMENT OF LABOR OTAA
Washington, D.C. 20210 DATE
April 26, 2021
ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 18-20
TO: STATE WORKFORCE AGENCIES
STATE WORKFORCE LIAISONS
STATE WORKFORCE ADMINISTRATORS
STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS
STATE LABOR COMMISSIONERS
TRADE ADJUSTMENT ASSISTANCE (TAA) LEADS
COMPREHENSIVE AMERICAN JOB CENTER MANAGERS
AFFILIATE AMERICAN JOB CENTER MANAGERS
FROM: SUZAN G. LEVINE
Principal Deputy Assistant Secretary
SUBJECT: Trade Adjustment Assistance (TAA) Financial Reporting Alignment and
Clarifications
1. Purpose. This Training and Employment Guidance Letter (TEGL) provides guidance on the
alignment of reporting requirements in the Participant Individual Record Layout (PIRL) and
the ETA-9130, while further providing information on how to document specific scenarios
within the submitted data.
2. Action Requested. States must inform all appropriate staff of the contents of these
instructions as soon as the guidance is distributed.
3. Summary and Background.
a. Summary – This document provides clarification on reporting requirements for the
following items:
i. General Reporting Alignment between the ETA-9130 and the PIRL
ii. Accrual Accounting Requirements on the ETA-9130 and the PIRL
iii. Alignment of Expenditure Subcomponents on the ETA-9130(M)
iv. Expenditures Reporting Requirements in the PIRL
1. Basic Requirements
2. Reporting Adjustments
3. Reporting Retroactive Payments
4. Expenditures for Co-Enrolled Participants and other Non-TAA Funds
5. Expenditures for Agent/Liable Participants
v. Improper/Overpayments in the PIRL
RESCISSIONS EXPIRATION DATE
None Continuing
b. Background – While numerous technical assistance materials have provided clarification
on these reporting requirements, clear guidance that comprehensively addresses these
reporting requirements have been lacking. As TAA Data Integrity (TAADI) has put
focus on the alignment of these reporting elements, the need for clear and comprehensive
documentation of the requirement has become apparent. Alignment between the PIRL
and ETA-9130 is essential to ensuring we have reliable measures of TAA expenditures
and TAA participant costs. This data is important to developing cost projections, funding
estimates, and program policy. In combination, these two sources allow us to better
understand broad expenditure strategies as well as detailed information on how services
are provided for specific groups. However, it is only if these two sources align that we
can construct a consistent understanding. SWAs also need to have consistent guidance
on how to address specific situations such as retroactive payments and overpayments.
4. General Reporting Alignment between the ETA-9130 and the PIRL
State Workforce Agencies (SWAs) are required to report accrued expenditures both in the
ETA-9130 and on the PIRL. The Department is able to utilize the ETA-9130 to track
aggregate expenditures including ones not specific to participations such as case management
and administration and the PIRL to assess how individual participant expenditures manifest
for different participant populations. In the majority of situations, SWA’s reporting between
the two collections should align such that the quarterly change in all active grants is equal to
the quarterly expenditure amounts for the PIRL as articulated in TAADI TEGL No. 01-19.
The Department recognizes some specific scenarios such as corrections to prior quarter
reporting, retroactive payments, recovered overpayments, and agent/liable expenditures not
aligning with responsibilities outlined in 20 CFR 618.824 may cause misalignment between
these two collections, but those situations should only affect a very small portion of total
expenditures.
5. Accrual Reporting Requirement
State Workforce Agencies (SWAs) are required to submit quarterly reports on the ETA-9130
with information on expenditures for the three TAA grant types received: (1) training and
other activities (TaOA), (2) Trade Readjustment Allowance (TRA), and (3) Alternative
Trade Adjustment Assistance or Reemployment Trade Adjustment Assistance (collectively
herein referred to as RTAA). Attachment I contains additional information on the types and
number of grants utilized by the TAA Program. SWAs are required to report expenditures on
the ETA-9130 based on accrual accounting as defined in 2 CFR 200.34(c), consistent with 2
CFR 2900.14, 20 CFR 618.860, and the form instructions including, but not limited to,
Federal Share of Expenditures (line 10e) and Total Administrative Expenditures (line 10f).
Further, SWAs are required to report expenditure subcomponents on the ETA-9130(M)
based on accrual accounting as defined in 2 CFR 200.34(c), consistent with 2 CFR 2900.14,
20 CFR 618.860, and the form instructions including, but not limited to, Case Management
Expenditures (line 11b), Job Search and Relocation Expenditures (line 11c), and Training
Expenditures (line 11d).
SWAs are required to report expenditures in the PIRL according to accrual accounting
consistent with 20 CFR 618.860. This requirement applies to all expenditure reporting
elements in the PIRL as detailed in Attachment II including training expenditures, job search
expenditures, relocation expenditures, TRA expenditures (by type), RTAA expenditures, and
overpayments.
SWAs are not required to convert accounting systems to use accruals, but SWAs must report
accrual information through best estimates based on an analysis of the documentation on
hand as indicated in 2 CFR 2900.14.
6. Alignment of Expenditure Subcomponents on the ETA-9130(M)
TAA TaOA grant expenditures exclusively include the expenditures of four subcomponents:
1. Total Administrative Expenditures (line 10f),
2. Case Management Expenditures (line 11b),
3. Job Search and Relocation Expenditures (line 11c), and
4. Training Expenditures (line 11d).
When SWAs report their TaOA expenditures on the ETA-9130(M), these four
subcomponents should add to the amount reported in Total Federal Share of Expenditures
(line 10e). If the subcomponents do not add to the Total Federal Share of Expenditures,
states should examine which expenditures are under- or over-reported and subsequently
correct the ETA-9130(M) information.
7. Expenditure Reporting Requirements in the PIRL
SWAs must report TAA quarterly and cumulative expenditures in the PIRL for training
expenditures, job search expenditures, relocation expenditures, TRA expenditures (by type),
RTAA expenditures, and overpayments as detailed in Attachment II. The below
requirements apply to expenditure reporting irrelevantly of the benefit or service category of
the expenditure.
Basic Requirements
As discussed in Section 4, all expenditures must be reported using accrual accounting. For
each of the types, SWAs must report a quarterly and cumulative expenditure amount.
Quarterly amounts indicate amounts that accrued in the quarter reported, and cumulative
amounts indicate the total accrued expenditure for that participation by the end of the quarter.
At the time of exit, the cumulative expenditures should represent the total expended for that
participation, but may be subject to adjustments and retroactive payment changes. Because
new accruals could only occur when new benefits or services are provided, quarterly accruals
should never occur after a participant exits unless a new participation was started.
Reporting Adjustments
The two types of adjustments that may occur to PIRL expenditure amounts are corrections to
previously reported values due to estimation errors or incorrect reporting and actual changes
to accrual amounts in the quarter.
For corrections to prior reporting amounts, there is no quarterly accrual, but SWAs
must correct the cumulative expenditure amount.
For accruals and negative accrual adjustments based on actions within the quarter,
SWAs must adjust the quarterly expenditure element as well as the cumulative.
For this reason, SWAs may report negative quarterly accruals in the PIRL during
participation. Once participation has ended, negative accruals do not occur except in some
retroactive payment and overpayment situations as detailed below.
Reporting Retroactive Payments
A retroactive payment occurs when a benefit is initially denied, but through an appeal or
similar process, the denial is overturned and the expenditure occurs. If the participant has not
yet exited, SWAs must report the expenditure normally. If a participant has exited, SWAs
should update the resulting cumulative amount but not the quarterly amount since it was a
benefit that would have occurred during participation absent the denial.
Expenditures for Co-Enrolled Participants and other Non-TAA Funds
Co-enrolled participants may receive training funded from multiple programs. Training
expenditures reported in the PIRL should only represent expenditures allocated to a TAA
TaOA grant. SWAs must report all training provided from any program, such as training
type and date entered training, but non-TAA funded trainings would report $0 in
expenditures. Other expenditures reported in the PIRL are specific to TAA-only benefits and
services so all expenditures will be TAA-funded.
While non-TAA funds are not reported in the PIRL, non-TAA funds should be reported on
the ETA-9130(M). Expenditures on TAA participants not funded by the TaOA grant, but
could have been (such as certain WIOA training expenditures) should be reported as Other
Federal Funds Expended (line 11a). Further, TAA participant expenditures funded by the
SWA rather than the TaOA grant should be reported in the Recipient Shares of Expenditures
(line 10k).
Expenditures for Agent/Liable Participants
While SWAs typically act in both agent and liable capacities as defined in 20 CFR 618.110,
there are some circumstances where an SWA acts only as agent State or liable State. SWAs
are required to submit a complete participation record in PIRL if they fulfill either agent or
liable role, unless DOL grants specific reporting flexibilities for particular data elements.
For PIRL expenditure reporting, the liable state is required to report all expenditure fields
irrelevantly of the state in which the expenditure occurred. Agent states are required to
report expenditure fields for training, job search, and relocation expenditures, but the
reporting of TRA and A/RTAA expenditures is optional.
8. Improper / Overpayments Reporting in the PIRL
An improper payment occurs when a payment was made either improperly or in the incorrect
amount as described in 2 CFR 200.53, and overpayments are improper payments where the
incorrect amount exceeds the correct amount. The recovery or waiver of overpayments must
comply with 20 CFR 618.832. The Department relies on detailed overpayment information
to meet requirements and determine overpayment rates for particular participant groups.
SWAs are required to report overpayment information on training, TRA, and RTAA
expenditures. SWAs must report the overpayment amount for these benefits and services as
the cumulative amount of all overpayments throughout participation irrelevantly of whether
that overpayment was recovered.
Overpayment information such as the overpayment flag and waiver information is
determined based on whether it occurred any point during the participation. As such, once an
overpayment occurs, that overpayment flag (not collected for training) and amount should be
reported in all subsequent reporting quarters in which that record is present. Similarly, the
overpayment waiver indicates that whether some or all of the overpayment was waived from
recapture. Once a waiver is issued, that waiver information should be reported in all
subsequent reporting quarters in which that record is present.
When an overpayment is recovered, overpayments should follow the reporting adjustments
guidance above and make the corresponding updates to the expenditure reporting elements.
Like retroactive payments, overpayment recaptures occurring after participation must adjust
the cumulative amounts, but does not change the quarterly accrual amount as it is correcting
expenditure information reported in a prior quarter.
9. Inquiries. Please direct inquiries to the appropriate Regional Office.
10. References.
Chapter 2 of Title II of the Trade Act of 1974, as amended (Pub. L. 93-618) (Trade
Act);
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, Final Rule;
2 CFR Part 618, Trade Adjustment Assistance Under the Trade Act of 1974, As
Amended;
2 CFR Part 2900, Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, Final Rule;
TEGL No. 20-19, Revised ETA-9130 Financial Report, Instructions, and Additional
Guidance;
TEGL No. 01-19, Trade Adjustment Assistance Data Integrity (TAADI);
OMB Control Number 1205-0521, WIOA DOL-only Participant Individual Record
Layout;
OMB Control Number 1205-0461, Employment and Training Administration –
Financial Report Form ETA-9130
11. Attachment(s).
Appendix I: Key Features of TAA ETA-9130 Reporting
Appendix II: PIRL Elements
Appendix III: Accrual Accounting Explanation
ATTACHMENT I – Key Features of TAA ETA-9130 Reporting
The TAA program operates through three types of grants: (1) Training and Other Activities (TaOA), (2) Trade Readjustment Allowances (TRA), and
(3) Reemployment Trade Adjustment Assistance (RTAA).
TaOA funds may be spent in the year funding is provided or the subsequent two years, which means that up to three TaOA grants may be active
for a State at any given time.
TRA and RTAA funds are one-year funds that align with the fiscal year.
For TaOA expenditures, funds for administration and case management are not trackable at the TaOA Total Federal Share of Expenditures (10e)
participant level and so are reported on the ETA-9130(M), but not on the PIRL. Further, the
expenditures for Job Search and Relocation benefits are tracked separately on the PIRL, but Job Search
Case
Adminstration and
combined (added together) for reporting on the ETA-9130(M). Furthermore, the sum of each (10f)
Management
Relocation
Training (11d)
(11b)
subcomponent should equal the total expenditures reported on line 10e (i.e. 10e = 10f + 11b + (11c)
11c + 11d).
For TRA expenditures, all TRA expenditures are combined on the ETA-9130(I) for reporting of Total Federal Share of Expenditures (10e). However,
the PIRL tracks each type of TRA separately to better articulate TRA utilization. TRA and RTAA use the same form, but as separate grants they have
separate submissions.
RTAA expenditures are tracked both on the ETA-9130(I) and the PIRL with a single set of elements. RTAA grants are used for expenditures both for
participants receiving Alternative Trade Adjustment Allowance (ATAA) under old versions of the program and RTAA under the current version of the
program.
ETA-9130 PIRL Expenditure Elements
Possible # of
Grant Type Form Expenditure Type Line Quarterly Cumulative
Active Grants
Administration 10f N/A N/A
Case Management 11b N/A N/A
TaOA 3 ETA-9130(M) Job Search PIRL 1506 PIRL 1507
11c (sum)
Relocation PIRL 1509 PIRL 1510
Training 11d PIRL 1324 PIRL 1325
Basic TRA PIRL 1514 PIRL 1515
Additional TRA PIRL 1519 PIRL 1520
TRA 1 ETA-9130(I) 10e (sum)
Remedial/Prerequisite TRA PIRL 1524 PIRL 1525
Completion PIRL 1529 PIRL 1530
A/RTAA 1 ETA-9130(I) RTAA 10e PIRL 1536 PIRL 1538
ATTACHMENT II – PIRL Elements
The PIRL tracks expenditures for eight types of benefits and services with a quarterly and cumulative expenditure element, which must report accrued
expenditures. Overpayment information is not collected for Job Search and Relocation, and there is no flag element for training overpayments. TRA
overpayments are combined across all types of TRA. All expenditure information is required for States that act in both an agent and liable role and
States that are liable only. Agent States are not required to report on TRA and RTAA expenditures, but may if they choose.
PIRL Element Type
Reporting Reporting
Quarterly Cumulative Overpayment
Overpayment Overpayment Required Required
Benefit or Service Expenditure Expenditure Waiver
Flag Element Amount Element for Liable for Agent
Element Element Element
States? States?
Training Costs - Training Costs -
Current Quarter Total Training
Amount of Overpayment
Training Training Expenditures Expenditures Not Collected
Overpayment Waiver
Yes Yes
(PIRL 1324) (PIRL 1325)
(PIRL 1326) (PIRL 1327)
Job Search Allowance Job Search Allowance
Job Search Current Quarter - Costs - Total Costs Not Collected Not Collected Not Collected Yes Yes
(PIRL 1506) (PIRL 1507)
Relocation Allowance Relocation Allowance
Relocation Current Quarter Costs -Total Cost Not Collected Not Collected Not Collected Yes Yes
(PIRL 1509) (PIRL 1510)
Amount Paid Current Total Amount Paid –
Basic Quarter-TRA Basic Basic TRA Yes Optional
(PIRL 1514) (PIRL 1515)
Amount Paid This
Total Amount Paid -
Quarter - Additional
Additional TRA
Additional TRA Yes Optional
(PIRL 1520)
(PIRL 1519)
TRA Amount of TRA TRA Overpayment
Amount Paid This
TRA Quarter -
Total Amount Paid - Overpayment Overpayment (PIRL Waiver (PIRL
Remedial/ Remedial/Prerequisite (PIRL 1531) 1532) 1533)
Remedial/Prerequisite
TRA
Yes Optional
Prerequisite TRA
(PIRL 1525)
(PIRL 1524)
Amount Paid Current
Total Amount Paid -
Quarter - TRA
Completion Completion
Completion TRA Yes Optional
(PIRL 1530)
(PIRL 1529)
A/RTAA
Current Quarter Total Amount Paid - A/RTAA Amount of A/RTAA
Overpayment
RTAA A/RTAA Payments A/RTAA Overpayment Overpayment
Waiver
Yes Optional
(PIRL 1536) (PIRL 1538) (PIRL 1541) (PIRL 1542)
(PIRL 1543)
ATTACHMENT III – Accrual Accounting Explanation
There is often confusion about how to translate the definition of accrual accounting into the normal financial flow in our programs. The following
explains how the accounting should occur based on typical TAA scenarios we see in SWAs, but it may differ depending on the specific financial and
contractual processes implemented. The definition for accruals is contained at 2 CFR 200.34(c); the explanations below are based on parts ii and iii.
Training Reporting on Accruals
The most typical flow in the TAA Program for training begins with a training approval, then enrollment, the start of training, an “add/drop deadline”
after which expenditures are still required if there is a withdrawal from training, an invoice, and a payment. See the diagram below.
Add/Drop
Training Start of Payment
Enrollment Deadline Invoice
Approval Training (Cash)
(Accrual)
There may be a substantial delay in the invoicing or payment for a training service received, but the date on which the amount accrues is the add/drop
deadline. After this date, the amount is owed for the training irrelevantly of whether it was invoiced or paid. Reporting expenditures based on cash
accounting or on invoice accounting is incorrect.
TRA and RTAA Expenditures
Expenditures for TRA and RTAA benefits generally follow a three-step process: (1) apply for benefit, (2) approval of benefit, (3) payment of benefit.
Approval
Apply Payment (Cash)
(Accrual)
In most circumstances, the benefit process occurs within a few days because all processes are internal to the SWA and not reliant on other parties.
Once a benefit is approved, the SWA has determined that the amount is owed and, thus, the accrual has occurred. Reporting expenditures based on
application or payment is incorrect. Job Search and Relocation expenditures are typically similar in process to TRA and RTAA with the accrual
occurring when expenditures are approved by the SWA.
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