Revised ETA-9130 financial reporting instructions

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                  Financial Reporting
               ADVISORY SYSTEM                             CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR
                                                           OGM
                                                           DATE
             Washington, D.C. 20210
                                                           April 29, 2020

ADVISORY:        TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 20-19

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

FROM:            JOHN PALLASCH
                 Assistant Secretary

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

1. Purpose. This guidance informs the workforce system of the revised Employment and
   Training Administration (ETA) financial report (ETA-9130) and associated instructions,
   including the addition of a new Training Expenditures line item on some of the ETA-9130
   forms. Additionally, it offers clarification on a pre-existing reporting line, apprises all ETA
   grant recipients of minor changes to the ETA-9130 due dates, and reminds grant recipients of
   ETA-9130 submission procedures.

2. Action Requested. Please disseminate this guidance to all staff that are either directly or
   indirectly responsible for financial management and financial reporting for ETA grants and
   cooperative agreements. Grant recipients will be required to submit their cumulative
   financial information using the revised ETA-9130 financial reports (as appropriate) by the
   due dates specified later in this document, starting with the reporting period for the quarter
   ending on June 30, 2020, and for all future reporting periods.

3. Summary and Background.

   a. Summary – This guidance provides information on new requirements for the continual
      tracking and reporting of training expenditures to support legislative requirements. It
      also provides clarification on one existing reporting line item, details minor changes to
      reporting due dates, and reminds grant recipients of the ETA-9130 reporting process.

   b. Background – Every grant awarded by ETA requires accurate quarterly and annual
      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,
   RESCISSIONS                                              EXPIRATION DATE
   TEGL 2-16                                                Continuing

      ensure sound service delivery and reporting practices, and determine whether the federal
      funds achieved maximum benefit.

      ETA requires all of its 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 revised
      versions of the ETA-9130 forms and instructions available for public comment, as
      required by the Paperwork Reduction Act (PRA), in a 60-day Federal Register Notice
      published at 84 FR 34947 on July 19, 2019, and through a 30-day Notice published at
      84 FR 51638 on September 30, 2019. The Office of Management and Budget (OMB)
      approved the new ETA-9130 financial reports on October 31, 2019 (OMB Control No.
      1205-0461), and extended the expiration date through October 31, 2022. The new forms
      and instructions are available at https://doleta.gov/grants/financial_reporting.cfm. The
      use of these new forms is required for all existing and new grant awards for the reporting
      period beginning with the quarter ending on June 30, 2020. Grant recipients must report
      cumulative figures on these new forms, starting from grant inception to the end of the
      reporting period, regardless of whether the reporting line is new or existed on the
      previous version of the applicable ETA-9130. Access to prior (older) versions of the
      ETA-9130 financial reports will remain for reports submitted for the quarters ending
      March 31, 2020, or earlier.

4. Financial Reporting Changes and Submission Instructions.

   Financial Reporting Changes. Several program-specific ETA-9130 financial reports
   now include a Training Expenditures line item. In addition, ETA is providing further
   guidance on the Indirect Expenditures reporting line.

   a. Changes to Program-Specific ETA-9130 Financial Reports – The ETA-9130s used for
      the Workforce Innovation and Opportunity Act (WIOA) statewide and local programs
      now contain a Training Expenditures reporting line. The following program-specific
      forms are impacted:

                 Statewide Grant Recipient Reports
                     1. Statewide Youth – ETA-9130(A)
                     2. Statewide Adult – ETA-9130(C)
                     3. Statewide Dislocated Workers – ETA-9130(E)

                 Local Grant Recipient Reports
                    4. Local Youth – ETA-9130(B)
                    5. Local Adult – ETA-9130(D)
                    6. Local Dislocated Worker – ETA-9130(F)

              i. Training Expenditures Reporting Guidance – The Training Expenditures
                 reporting line should consider all costs for training, including, but not
                 limited to:
                        1. All tuition costs and materials: books, tools, etc., as applicable.

                               2. All forms of training must be accounted for, including but not
                                  limited to: occupational skills training; school equivalency
                                  (General Education Development/High School Equivalency
                                  Test/Testing Assessing Secondary Completion) training;
                                  Registered Apprenticeship Programs (RAPs); Industry
                                  Recognized Apprenticeship Programs (IRAPs); on-the-job
                                  training (OJT); incumbent worker training1; and customized
                                  training.

    b. Clarification for the Indirect Expenditures (Line 13) Reporting – While there are no
       definitional reporting changes related to this line item, ETA is providing the following
       additional clarification. Recipients should report indirect expenses incurred by the non-
       federal entity receiving direct awards from DOL, using an indirect cost rate from an
       approved Negotiated Indirect Cost Rate Agreement (NICRA). Recipients and/or sub-
       recipients using a Statewide Cost Allocation Plan (SWCAP) are still required to report
       indirect expenditures using their approved allocation. Grant recipients that have both a
       NICRA and SWCAP should report indirect expenditures using the NICRA only.

    Submitting Financial Reports. The electronic, online process to submit and certify
    ETA-9130 financial reports remains unchanged. Nonetheless, ETA continues to receive a
    significant number of questions from recipients on submitting ETA-9130 financial
    reports. For this reason, ETA has included information in this section on how to create
    and update accounts on ETA’s financial reporting site, in addition to discussing the
    reporting process and minor changes to the associated deadlines.

    c. Financial Reporting Site Access – Recipients need a username, password and
       Personal Identification Number (PIN) to be able to certify and submit their ETA-9130
       financial reports at http://www.doleta.gov/grants/financial_reporting.cfm.

        New Access:

        Recipients should request access to the online financial reporting system immediately
        upon receipt of the grant award to ensure timely report submission. The Financial
        Reporting Access Request Document is available at
        http://www.doleta.gov/grants/financial_reporting.cfm. Recipients must provide
        contact information for both the designated authorizing official (the individual
        responsible for certifying the accuracy of the ETA-9130 financial reports) and the
        secondary contact (the individual responsible for entering the data into the ETA-9130
        financial reports) on the Financial Reporting Access Request Document. Once
        completed, recipients must submit the form via email to [email protected].
        After ETA receives the access request, the primary contact will receive a temporary
        password via email.

1
  Note that incumbent worker training expenditures are required to be reported under 11g of the 9130(D) and (F)
reports. These expenditures should be included in the Training Expenditures line on the ETA-9130 as well.

   The primary contact must go to the online financial reporting website at:
   https://etareports.doleta.gov and create login credentials for the grant using the
   temporary password. The system automatically generates a username (the primary
   contact’s email address) and asks the primary contact to create a new password
   (passwords expire every 60 days). Upon successful completion, the primary contact
   will receive a confirmation email from the system with the username and PIN to
   certify the ETA-9130 financial reports. The primary contact shares the username and
   password with the secondary contact to allow that individual to access the online
   financial reporting system, but keeps the PIN to certify the ETA-9130 financial
   reports. The system automatically deactivates user accounts after 90 days of
   inactivity.

   Updates to Contact Information:

   Recipients must ensure that the primary contact’s information remains current
   and correct. If more than one grant agreement requires a change in contact
   information, please send an email to [email protected] that lists all
   the grant agreement numbers affected by the change. Recipients should then
   follow the procedures identified above under New Access.

d. Reporting Guidance

           i. General – Recipients must submit an ETA-9130 financial report for each
              subaccount listed on the 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 these instances,
              recipients must develop and report accrual information through best
              estimates based on an analysis of the documentation on hand.

          ii. When to Submit the Initial ETA-9130 – The effective date listed on the
              NOA for the grant determines the due date for the initial ETA-9130
              financial report. The date the Grant Officer signs the NOA has no bearing
              on this determination, as shown in the examples in the following chart:

                  NOA                Date       Initial Reporting          Initial
                 Effective           NOA          Quarter End              Report
                   Date             Signed             Date                 Due
                                                                            Date
                    7/1/19          7/1/19               9/30/19           11/15/19
                   10/1/19        12/28/19               12/31/19           2/15/20
                    8/1/20         9/28/20               9/30/20           11/15/20
                   7/15/20         10/2/20               9/30/20           11/15/20

iii. Due Dates – ETA-9130 financial reports are due no later than 45 calendar
     days after the end of each quarter, as shown in the chart below.

                 Quarter End                             Financial
                     Date                              Reports Due
                   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. The
     online financial reporting system is available 24 hours a day, 7 days a
     week. However, reporting system technical support is only available on
     weekdays. See section 6.d below for instructions on how to obtain online
     technical assistance.

iv. End of Grant Reporting – Upon the expiration of a grant, the grant recipient
    must submit two reports:

           1. The Final ETA-9130 – Submitted no later than 45 calendar days
              after the reporting period in which the grant POP expires or the
              expenditure of all funds, whichever comes first. To designate
              an ETA-9130 as the final one, the recipient must check “Yes” in
              box #6, Final Report. Not checking “Yes” in box #6 can delay
              access to the Closeout report.

           2. The Closeout ETA-9130 – Submitted no later than 90 calendar
              days after the POP end date. The ability to submit a Closeout
              ETA-9130 becomes available in the reporting system after the
              submission of the Final ETA-9130. The closeout package is at
              https://www.etareports.doleta.gov/CFDOCS/grantee_prod/
              reporting/index.cfm.

     The following chart provides examples of due dates for the Final and
     Closeout ETA-9130 reports:

                                          All Funds           Final               Final    Closeout
                  Grant POP               Expended          Reporting           Report     Report
                                           or POP           Quarter               Due        Due
                                           Expired          End Date              Date      Date*
                 7/1/17 – 6/30/20          6/30/20           6/30/20             8/15/20    9/28/20
                10/1/17 – 9/30/20          9/30/20           9/30/20            11/15/20   12/29/20
                 8/1/19 – 7/31/20           1/6/20           3/31/20             5/15/20   10/29/20
               * Closeout ETA-9130 reports are due 90 calendar days after the expiration of the POP
                 regardless of whether funds are expended prior to that date.

e. Report Submission Process

          i. Data Entry – The secondary contact designated by the recipient
             organization (per the procedure discussed in section 4.c) is responsible for
             entering the required ETA-9130 data using the password.

             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 are on a cash
             basis.

         ii. Data Certification – The primary contact, the designated authorized
             official in the recipient organization, is responsible for certifying the
             accuracy of the data by entering the PIN. As the PIN takes the place of a
             signature to certify the data and officially submit the report, the grant
             recipient is responsible for ensuring that the designated authorized official
             is a current employee. The PIN allows access to a U.S. Government
             database and must not be used by anyone other than the individual to
             which it was assigned.

         iii. Data Acceptance – ETA staff will review and either accept 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 populate the
              Rejection Reason Section with the reason for the rejection and separately
              notify the grant 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.

              iv. Revisions to Prior Reports – A recipient cannot revise a previously
                  submitted ETA-9130 financial report once ETA has accepted ETA-9130
                  financial reports for two successive quarters. Additional adjustments on
                  prior quarter locked reports may occur only in limited circumstances and
                  with approval from ETA. 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.

5. Inquiries. Please direct inquiries as follows, based on the subject of the inquiry:

   a. Questions on this TEGL – Please contact your assigned Federal Project Officer (FPO) or
      the appropriate Regional Office.

   b. Assistance with Completing the ETA-9130 Financial Reports – Please direct requests to
      your assigned Regional representative.

   c. Questions on the Closeout 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 Grantee
      Reporting System Helpdesk at [email protected], and copy your assigned
      FPO.

       To facilitate an expeditious response, please include the following information in your
       technical assistance (TA) request:
            Grant Recipient Name
            Grant Number
            Quarter End Date of the Report Needing TA
            Contact Name and Telephone Number
            Description of the TA issue

   e. Grant Closeout Information – please visit
      http://www.doleta.gov/grants/grant_closeout.cfm.

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
      One-Stop Comprehensive Financial Management Technical Assistance Guide (TAG)
       Part II (https://www.doleta.gov/grants/pdf/TAG_PartII_July2011.pdf)
      Paperwork Reduction Act of 1995 (PRA), codified at 44 U.S.C. §§ 3501–3521

7. Attachments. Not applicable.