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1. Fiscal Definitions

Grantees must use grant funds in accordance with signed assurances and the approved grant proposal. Expenses must be in compliance with federal and state requirements and be reasonable, necessary, allowable and allocable.

Administrative Costs (AELA)

Administrative costs may not exceed 5% of the total award.

Administrative costs are costs that don’t directly involve a learner. It includes but is not limited to planning; administration (including performance accountability); professional development; and promoting co-enrollment.

Allowable Cost

  1. Necessary - The cost is required for the proper and efficient performance and administration of the grant. Program goals and objectives outlined in the grant proposal can be a helpful lens for determining if the cost is necessary for either programming or management required to implement the approved grant.
  2. Reasonable - The cost is an amount that a reasonable person would expend. Another way to determine reasonable cost is to assess the market value of comparable goods or general recognition that the cost is ordinary and necessary for the performance of the grant.
  3. Allocable - The cost is allocable in relation to the benefit that particular grantee receives. If a grant charges 100%of a cost to the grant then the entire benefit (100%) from the expenditure must serve the purpose of the grant.
  4. Allowable (AEFLA) - The cost is permitted under AEFLA as well as EDGAR and Uniform Grant Guidance (PDF).
  5. Allowable (AELA) - The cost is permitted under AELA (PDF) and State Board of Education Rules (PDF)

Allowable Expenses (AEFLA)

This information is provided to assist grantees in determining the allowability of costs under the federal AEFLA Grant. This guidance is for expenditures paid with the Federal funds, match expenditures and the program income generated as a direct result of the AEFLA Grant.

All costs must:

  • Be necessary and reasonable, and allocable,
  • Conform to any limitations or exclusions set forth in the cost principles or the award,
  • If grantees are applying policies and procedures across the organization, this must also include all activities within the AEFLA grant program.
  • Be accorded consistent treatment,
  • Be determined in accordance with Generally Accepted Accounting Principles (GAAP),
  • Not included in another grant,
  • Ensure amount charged for a purchase paid from the AEFLA grant includes credits, and
  • Be adequately documented and reported.

Additional guidance can be found in the federal Uniform Grant Guidance.

The list below shows allowable and unallowable costs for AEFLA funds. Note this list is not comprehensive. Expenditures must follow the Uniform Grant Guidance, EDGAR, Cost Principles, Audit, and be permitted by the WIOA Title II and WIOA Title II rule and Joint Rule.

Allowed

  • Program Personnel costs including benefits. All personnel costs must be for services provided to eligible individuals as defined by WIOA. No exceptions. Navigator positions are allowable position costs.
  • Program Compensation-fringe benefits includes social security, employee life, health, unemployment, and worker’s compensation insurance (except as noted in 2 CFR §§200.447 Insurance and indemnification); pension costs and other similar benefits are allowable, provided such benefits are granted under established, written program policies.
  • Administrative personnel costs including benefits are allowed within the approved administrative cost percentage the grantee received from CDE.
  • Professional Development—In State
  • Professional Development-Out of State-Must receive prior approval.
  • Supplies - classroom and staff consumables
  • High School Equivalency practice tests
  • ABEA application fee and fingerprinting
  • Audits - only the part allocable to the AEFLA Grant. Audit must be documented and receive prior approval.
  • Travel per the grantee’s travel reimbursement policy.
  • Cost of communicating grantee offerings including printing and flyer distribution.
  • Child care costs if the grantee is providing family literacy activities. Local program must first attempt to coordinate with other programs and services in the local area prior to using AEFLA funds.
  • Costs associated with Integrated Education and Training. Grantees should first attempt to coordinate with postsecondary education providers or employer/other training providers for the workforce training component prior to using AEFLA funds.
  • Transportation costs associated with student engagement in the program. Grantees must provide anticipated number of learners served.

Not Allowed

  • Contingencies - This includes a budget line that states-funds will be held for professional development however the needs are not known at this time.
  • Fundraising
  • Entertainment Costs
  • Gift cards
  • Food costs, including snacks
  • Incentives to staff/participants/volunteers, including luncheons
  • Fines, Penalties
  • Legal Expenses
  • Political activities
  • Lobbying costs
  • Grant writing
  • Vacation time - This cost should be accrued by the agency and not charged to the AEFLA Grant.
  • High School Equivalency assessments
  • Course costs related to obtaining the ABEA
  • Tuition and fees that create barriers. Reference the Program Income Policy
  • Promotional materials such as pens, hats, shirts and water bottles.

Allowable Expenses (AELA)

This information is provided to assist grantees in determining the allowability of costs under the state AELA Grant.

All costs must:

  • Be necessary and reasonable, allocable and allowable;
  • Focus on programs that prepare individuals for training leading to occupations that have the potential to pay a self-sufficient wage.
  • Conform to any limitations or exclusions set forth in the award; 
  • If grantees are applying policies and procedures across the organization, this must also include all activities within the AELA grant program.
  • Be accorded consistent treatment,
  • Be determined in accordance with Generally Accepted Accounting Principles (GAAP),
  • Not included in another grant,
  • Ensure amount charged for a purchase paid from the AFLA grant includes credits, and
  • Be adequately documented and reported.

The list below shows allowable and unallowable costs for AELA funds. Note this list is not comprehensive.

Allowed

  • Advertising Costs
    • The advertising costs associated with student recruitment is allowed. The grant will cover the cost of flyers, brochures that are created to promote AELA program activities. These costs must be reasonable.
  • Child care
    • Child care costs are allowable as it relates to providing childcare for children of parents participating in AELA programming.
  • Curriculum development
    • Curriculum development for courses that assist adults in obtaining basic skills in workforce development or postsecondary transition and integrated education and training.
  • Employment placement costs
  • Equipment
    • Teacher - The grant will cover the cost of a computer for teachers paid with the grant funds. The cost must be allocable. Example: If a teacher will be hired .50 FTE for grant activities and .50 FTE will be spent addressing other agency needs, only half of the computer would be allocable to the grant and the balance would need to be paid from other funding sources.
    • Student - Due to limited funding, grantees must provide support for the use of grant funds to purchase laptops. The allocability of the cost to the grant will need to be reviewed to ensure the grant is not paying 100% for equipment that will be used by other programs within the agency.
  • Food Costs
    • The grant will cover the cost of food costs for parent and student activities/meeting. This must relate to the grant with a copy of the agenda included as supporting documentation.
  • Partnership development
    • Including one-time infrastructure expenses, print materials, outreach activities, and travel.
  • Professional Development for staff paid with grant funds
    • Professional development is available for staff whose salary and benefits are paid directly by the AELA Grant. Professional development must align with the approved project goals outlined in the approved application.
  • Professional Development-out-of-state
    • Prior approval from AEI required. Grantees will be required to submit an Out-Of-State Request Form that includes a rationale for the need to travel out of state i.e., the professional development is not offered in the state and only minimal (one or two) will attend.
  • Professional development for all staff of an agency
    • Professional development that a grantee would like to offer to the entire staff of an agency will be required to submit rationale that supports the need to provide this training to all staff. Within the explanation the grantee should state if other funds would be available to support this training.
  • Professional Development to partners
    • The AELA Grant does require that recipients of the grant provide professional development to its partners.
  • Testing Fees
    • The cost of enrollment/testing fees will be covered if they are reasonable and are supported by the number of students receiving services from the grantee. This includes: ConOver/Workforce, Prove It, GED, HiSET, and TASC.
  • Transportation
    • Transportation costs associated with student engagement in the program are allowed. Grantees must ensure appropriate documentation is maintained for these costs.  Grantee must provide anticipated number of students to be served and an estimated cost per student.
  • Work-experience costs
    • This includes uniform costs, instructional materials, and assessment costs. 

Not Allowed

  • Indirect costs
    • Indirect cost is not allowed under this grant. All costs must be direct costs that are well-documented.
  • Staff certification and continuing education
    • Certification that is part of training is not an allowable cost. The grant also doesn’t allow for the cost of continuing education requirements.
  • Lobbying costs

 

Carry Over

Grant funds cannot be carried over from one fiscal year to the next. Funds must be spent during the fiscal year (July 1-June 30). If grantees do not obligate funds by June 30, grantees will need to revert funds back to CDE.

AEFLA

The grantee will have until September 15th after the fiscal year ends to request for final reimbursement of the previous fiscal year’s funds. Funds not requested after that time will revert back to CDE.

AELA

Any unobligated funds must be reported on the Annual Financial Report submitted September 30th of each year.

Fund Types (AEFLA)

WIOA Title II AEFLA funds (ie: federal funds), match funds and program income (if applicable) are used to fund the AEFLA program. Information about each time of funding is provided below.

Federal Funds

  • Federal funds are the funds a sub-grantee receives under Title II of WIOA.
    • Grantees are required to spend their AEFLA and IEL/CE grant funds on costs that follow 2 C.F.R. Part 200 and are part of their approved budget. All costs must be reasonable, necessary, allowable, allocable and documented.
    • Under Sec. 233 of WIOA there is a 5% maximum administrative cap for the funds awarded under AEFLA and IEL/CE. Grantees may request approval from AEI to utilize up to 10% of federal funds on administrative costs. If a grantee is aware they will exceed the 5%, they must receive prior written approval.
      • Note: A grantee may charge indirect costs to the AEFLA Grant, however, the grantee may not request more than 10% of their federal allocation for indirect costs and administrative costs combined. This is true even if the local program has an indirect cost plan with another state agency. Per federal law, those indirect cost plans cannot apply to AEFLA funds.

Match requirement

  • All grantees must secure non-federal match funds that are no less than 40% of the federal funds received.
  • Match funds and third party in-kind contributions may not count if they are satisfying a cost sharing or matching requirement of another agreement, a Federal procurement control or any other Federal funds.
  • Match funds are not required to follow the maximum administrative cost limitations set forth in WIOA.
  • Funds identified as match can be used based on the need of the grantee, as long as they are reasonable, necessary, allowable under WIOA, allocable and documented.
  • Documentation for all match must be maintained at the same level as the federal funds expended.

Program Income

Program income is additional income directly generated by a grant supported activity, or earned only as a result of the grant agreement during the grant period. An example of program income is charging student fees for classes.

  • All expenditures paid with program income must follow the same requirements as the federal award including allowable costs and compliance with the Uniform Grant Guidance.
  • Program income generated under AEFLA must be accounted for and reported separately from federal funds.
  • Cannot count towards a match requirement on this or any other federal grant.
  • Program income must be used in the year it was earned.
  • The program income funds are not required to follow the maximum administrative cost limitations set forth in WIOA.
  • Funds identified as program income can be used based on the need of the grantee, as long as they are reasonable, necessary, allowable under WIOA, allocable and documented.
  • Documentation for all program income must be maintained at the same level as the federal funds expended.

Serving Corrections Individuals (AEFLA)

Statewide, no more than 20% of funds available for distribution may be used for corrections education. There is not a cap at the grantee level. Corrections education is defined as criminal offenders (ie: individuals charged with or convicted of a criminal offense) who reside in correctional institutions (WIOA Title II, Section 225).

Supplement vs Supplant

AEFLA

Grantees may not supplant (substitute/divert) funds using AEFLA funds. Supplement, not supplant is an integral provision of most federal statutes that authorize grant programs. This requires that grantees use state or local funds for all services required by state law, State Board of Education rule, or local policy and prohibit those funds from being diverted for other purposes when federal funds are available. Federal funds must supplement (Ie: add to enhance, expand, increase or extend) the programs and services offered with state and local funds. If services would be provided in the absence of this grant, by using federal grant funds to cover any portion of these services, it would be considered supplanting.

AELA

All expenditures must supplement not supplant any federal, state or local money currently being used to provide adult education and literacy services. Funds must supplement (i.e.: add to enhance, expand, increase or extend) the programs and services offered with state and local funds. If services would be provided in the absence of this grant, by using federal grant funds to cover any portion of these services, it would be considered supplanting.

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