Attachment D Infrastructure Funding Agreements, Cost Allocation Methodology, Other Shared Costs

Transcription

1 Attachment D Infrastructure Funding Agreements, Cst Allcatin Methdlgy, Other Shared Csts Infrastructure Funding Agreements (IFA) The advantages f Lcal WDBs establishing self-negtiated, successful IFAs under the lcal funding mechanism include the fllwing: Lcal autnmy Under the lcal funding mechanism, decisins remain at the lcal level which ensures the IFAs will be tailred t each Lcal Area s unique needs. Strnger reginal partnerships The mre each partner can have a direct say in the lcal negtiatins, the strnger the partnerships will be. N caps n partner cntributins Under the state funding mechanism, specific caps are set n the amunt and percent f each partner s funds that may be cntributed. Hwever, under the lcal funding mechanism there are n caps. Flexibility n funds used Title I prgrams are allwed t use prgram funds t pay their prprtinate share f the infrastructure csts when negtiating under the lcal funding mechanism. If the state funding mechanism is triggered, Title I prgrams may be required t pay their prprtinate share nly ut f administrative csts. Establishing Infrastructure Funding Agreement (IFA) Budgets When establishing the IFA budgets, Lcal WDBs have tw ptins: 1. Develp a separate budget fr each WSO Center. 2. Develp a cnslidated system-wide budget fr the netwrk f WSO Centers. If a Lcal Area has mre than ne WSO Center, develping a cnslidated budget based n the netwrk f WSO Centers may make financing infrastructure csts amngst partners easier since it des nt require each partner t cntribute t each WSO Center, s lng as each partner s ttal cntributin is still equal t their verall prprtinate share. The cnslidatin f budgets cannt change the distributin f csts in any way, csts must be still attributable t each partner equally and in accrdance with the agreed upn cst sharing methdlgy. Whichever ptin is selected, all partners must agree t the budget and cst allcatin methdlgy. They must als meet the standards f prprtinate use and relative benefit and cmply with federal cst principles. The IFA budgets include, but are nt limited t, all nn-persnnel csts that are necessary fr the physical peratin f the WSO Center such as: rent, utilities and maintenance, equipment, technlgy, and nn-marketing cmmn identifier expenses. Every WSO Center infrastructure budget must als have an Access and Accmmdatin line item fr ensuring physical and prgrammatic access t the WSO Center by individuals with disabilities. The budgets must cntain descriptins f the specific csts gruped under each line item. Lcal WDBs may cnslidate and/r break ut line items as best fits with their individual area budgets and cst allcatin methdlgy. Examples f csts that may fall under the abve mentined line items include, but are nt limited t, the fllwing: Rental f the Facilities Utilities and Maintenance Csts

2 Attachment D Infrastructure Funding Agreements, Cst Allcatin Methdlgy, Other Shared Csts Electric Gas Water Sewer cnnectins High-speed internet cnnectivity Telephnes (landline fr the center, nt cell phnes) Facility maintenance cntracts Equipment Csts Assessment-related prducts Assistive technlgy fr individuals with disabilities Cpiers Fax machines Cmputers Other tangible equipment used t serve all center custmers (nt specific t an individual prgram partner) Technlgy t Facilitate Access t the WSO Center Csts Technlgy used fr the center s planning and utreach activities Cst f creatin and maintenance f a center website (nt specific t an individual prgram partner) that prvides utreach t custmers by prviding infrmatin n WSO Center services and/r prvides direct service access t WSO Center services Please nte, this des nt include data systems r case management systems specific t individual prgram partners. Cmmn Identifier Csts (Lcal ptin) Creating new signage Updating templates and materials Updating electrnic resurces Nte: If a Lcal WDB decides t include cmmn identifier csts as part f the IFA, they cannt include csts assciated with any srt f advertising campaign prmting the WSO Center under the new cmmn identifier (WIOA Jint Final Rule Preamble page 55904). Determining Benefit Received by Partners Lcal WDBs must first determine whether a WSO Center Partner is receiving benefit frm the WSO Center r system. If benefit is being received, the WSO Center Partner s prprtinate share f infrastructure csts must be calculated in accrdance with Unifrm Guidance and based n a reasnable cst allcatin methdlgy, whereby infrastructure csts are charged t each partner in prprtin t their use f the WSO Center(s). All csts must be allwable, reasnable, necessary, and allcable (20 CFR ). Partners wh are physically c-lcated in the WSO Center(s) (full-time r part-time) are cnsidered t receive a direct benefit that is allcable, therefre, they must cntribute their prprtinate share twards infrastructure csts. Partners wh are nt physically c-lcated in

3 Attachment D Infrastructure Funding Agreements, Cst Allcatin Methdlgy, Other Shared Csts the WSO Center may als be receiving benefit frm the WSO Center system. Hwever, that benefit still has t be clearly allcable by way f reliable data and a cst methdlgy that demnstrates the partner s usage f and benefit frm the center and its services. T remain in cmpliance with Unifrm Guidance cst allcability rules, the requirement t cntribute t infrastructure csts at this time nly applies t thse partners wh are physically c-lcated in the WSO Centers. Hwever, it is imprtant t nte that nn-clcated partners are still required t cntribute t ther system csts based n their prprtinate share f applicable career services as identified in Part I f the MOU, as well as any additinal line items the Lcal WDBs and WSO Center Partners agree t include in the ther system csts budget. Cst Allcatin Methdlgy After determining whether an IFA will be created fr each WSO Center, r ptinally, fr the lcal netwrk f WSO Centers as a whle, and determining if benefit is received by each partner, the Lcal Bard must select a cst allcatin methdlgy t identify the prprtinate share f infrastructure csts each partner will be expected t cntribute. Any cst allcatin methdlgy selected must adhere t the fllwing: Be cnsistent with the federal laws authrizing each partner s prgram (including any lcal administrative cst requirements). Cmply with federal cst principles in the Unifrm Guidance. Include nly csts that are allwable, reasnable, necessary, and allcable t each prgram partner. Be based n the prprtinate use and if benefit is received by each partner. Examples f cst allcatin methds that may be used include, but are nt limited t, the fllwing: The prprtin f a partner prgram s ccupancy percentage f the WSO Center (square ftage). The prprtin f a partner prgram s custmers cmpared t all custmers served by the WSO Center. The prprtin f partner prgram s staff amng all staff at the WSO Center. The prprtin f a partner prgram s use f equipment at the WSO Center. Cash, In-Kind, r Third-Party In-Kind Cntributins WSO Center Partners (r their respective state entity) may prvide cash, nn-cash, and thirdparty in-kind cntributins t cver their prprtinate share f infrastructure csts. If nn-cash r in-kind cntributins are used, they cannt include nn-infrastructure csts (such as persnnel), and they must be valued cnsistent with Unifrm Guidance Sectin t ensure they are fairly evaluated and meet the partner s prprtinate share (20 CFR ). If third-party in-kind cntributins are made that supprt the WSO Center(s) as a whle (such as space), that cntributin will nt cunt tward a specific partner s prprtinate share f

4 Attachment D Infrastructure Funding Agreements, Cst Allcatin Methdlgy, Other Shared Csts infrastructure. Rather, the value f the cntributin will be applied t the verall infrastructure csts and thereby reduce the cntributin required fr all partners. When determining the use f nn-cash and in-kind cntributins, verall csts must be kept in mind as there must first be enugh cash cntributins t cver thse. Determining the Surce f Funds t Pay Infrastructure Csts When determining which funds can be used t pay infrastructure csts, WSO Center Partners must remain in cmpliance with their authrizing federal statute as well as 20 CFR , which prvides stipulatins n the types f funds certain partners are allwed t use twards their prprtinate share under the lcal funding mechanism. These limitatins include the fllwing: WIOA Title I Infrastructure csts can be paid as prgram and/r administrative csts. WIOA Title II Infrastructure csts can nly be paid frm funds available fr lcal administrative expenses r frm nn-federal resurces that are cash, in-kind, r thirdparty cntributins. WIOA Title III As the regulatins did nt specify a funding surce fr Title III, any available funds may be utilized fr infrastructure csts. WIOA Title IV Infrastructure csts are paid frm administrative csts. Career and Technical Educatin Infrastructure csts must be paid frm funds available fr lcal administrative f pstsecndary level prgrams and activities t eligible recipients, r a cnsrtia f eligible recipients, and may be paid frm funds made available by the state r nn-federal resurces that are cash, in-kind, r third-party cntributins. TANF/JOBS Infrastructure csts are paid nly frm thse funds used fr the prvisin r administratin f emplyment and training prgrams. There are n set caps n the amunt r percent f verall funding an WSO Center Partner is respnsible fr cntributing t fund infrastructure csts under the lcal funding mechanism, except that cntributins frm administrative csts may nt exceed the amunt available fr administrative csts under the authrizing statute f the partner prgram. SNAP Emplyment and Training -??? There are n set caps n the amunt r percent f verall funding a WSO Center Partner is respnsible fr cntributing t fund infrastructure csts under the lcal funding mechanism, except that cntributins frm administrative csts may nt exceed the amunt available fr administrative csts under the authrizing statute f the partner prgram. Cmment [KRT1]: Check with DHS fr their interpretatin. Other Shared Csts Unlike the IFA, ther system csts are nt limited t the nn-persnnel csts f perating a WSO Center. They can include shared persnnel csts such as a center receptinist r staff wh are crss trained in and deliver services fr multiple partner prgrams. Everything in the ther system csts budget must be agreed t by all partners lcally. There is n state funding mechanism fr ther system csts that will be triggered due t lack f agreement at the lcal level.

5 Attachment D Infrastructure Funding Agreements, Cst Allcatin Methdlgy, Other Shared Csts As with infrastructure csts, ther system csts must be allcable accrding t the prprtin f benefit received by each f the WSO Center Partner prgrams, cnsistent with the partner s authrizing federal statute and Unifrm Guidance. The methd(s) fr allcating ther system csts can include thse allcatin methds identified fr infrastructure csts as well as ther apprpriate methds including, but nt limited t, the prprtin f a partner prgram s service cunts. The MOU must als include an agreed upn budget fr these ther csts alng with the agreed upn cst sharing methdlgy. Establishing Other System Csts Budgets The agreed upn budget fr ther shared csts must align with Part I f the MOU that utlines shared custmers and services. The ther shared csts budget can be a part f ne verall WSO Center system budget (including infrastructure) r it can be develped and described separately. The ther shared csts budget must include a line item fr applicable career services. Part I f the MOU requires identificatin f the career services that are applicable t each partner prgram. Accrdingly, this budget must include each f the partner s csts fr the service delivery f each applicable career service and a cnslidated system budget fr career services applicable t mre than ne partner. The budget may als include shared services, which have been agreed upn by all partners, which are authrized fr and may be cmmnly prvided thrugh the WSO Center system. Examples f these types f services include, but nt limited t, the fllwing: Initial intake, assessment f needs, appraisal f basic skills, identificatin f apprpriate services t meet such needs, and referrals t ther WSO Center Partners. This may include csts such as technlgy and tls that increase integrated service delivery thrugh the sharing f infrmatin and service delivery prcesses. Business services. This may include csts related t a lcal r reginal system business services team that has ne r mre partners n the team r has delegated a specific partner t prvide business services n behalf f the system. WSO Center Partner staff crss training. This may include any staff crss training n partner prgrams and eligibility identified in the Part I. One-Stp peratr. This may include the system rle f the One-Stp peratr (e.g., crdinating service prviders acrss the WSO Center delivery system) when the rle is nt specific t the peratin f the WSO Center and/r specific partner prgrams, s lng as the rle was defined by the Lcal WDB in the prcurement prcess and agreed t by all WSO Center Partners in the MOU. Shared persnnel (and ther nn-infrastructure csts) fr c-lcated partners. This may include center receptinists and/r center managers. Prcess and Develpment The guidance presented in Determining Benefit Received by Partners (abve) als applies t ther shared csts.