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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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