AEFLA Funding FAQs

Purpose

This Q&A provides answers to questions submitted by prospective grant applicants.  The categories below include:

1. Allowable Use of Funds

2. Eligible Individuals

3. Budget/Fiscal

4. Funding Distribution

5. Integrated English Literacy and Civics Education Program Funding

6. Integrated Education and Training

7. Shared Infrastructure Costs 

8. Local Workforce Development Board Review 

9. Eligibility

10. Grant Application

11. Assurances

12. Other

Allowable Use of Funds

Q: I remember seeing a list of allowable expenses with previous grants. Do we have one for this new go-round?

A: As noted in the application, allowable use of funds for Adult Education and Literacy Services (WIOA Sec. 222(a)(1)) must be used to establish or operate at least one or more of the following activities within each Local Workforce Development Area to be served: 

1. Adult Basic Education (ABE; below the ninth-grade level, NRS Educational Functioning Levels 1-4)
2. Adult Secondary Education (ASE; ninth – twelfth grade level, NRS Educational Functioning Levels 5-6)
3. English as a second language (ESL, NRS ESL Levels 1-6)
4. Integrated English Literacy and Civics Education (IELCE)
5. Corrections Education

In addition, applicants may include a provision of services and instruction for one or more of the following categories within each Local Workforce Development Area to be served:

1. Workplace Adult Education and Literacy;
2. Family Literacy Services;
3. Workforce Preparation Activities;
4. Integrated Education and Training;
5. Corrections Education;

Funding should be used to establish or operate programs that provide adult education and literacy activities, including programs that provide such activities concurrently.

Allowable local administrative costs include planning; administration (including performance accountability); professional development; providing adult education and literacy services in alignment with local workforce plans, including promoting co-enrollment; and carrying out one-stop partner responsibilities, including infrastructure costs. Further, funded applicants will be given the opportunity to negotiate local administrative costs.

Q: Is corrections a priority group?

A: Within the Adult Education and Family Literacy Act (AEFLA), WIOA Sec. 225 focuses specifically on programs for corrections education and other institutionalized individuals. According to WIOA Sec. 225(a), it states that “from funds made available under section 222(a)(1) for a fiscal year, each eligible agency shall carry out corrections education and education for other institutionalized individuals.”

Q: How many learners must be served with a grant award between $100,000-$500,000+?

A: A cost per learner is not specified in the grant application. Under the Uniform Grant Guidance (UGG) §200.400(E) , expenses must be reasonable, allowable and allocable. Applicants must explain in Section E of the application how the costs of the proposed project are reasonable and the budget is sufficient to implement the proposed activities. 

Eligible Individuals

Q: Can you define an "adult" learner?

A: According to WIOA Title II, eligible individuals are those 1) who have attained 16 years of age, 2) who are not enrolled or required to be enrolled in secondary school under State law; and 3) who are basic skills deficient; do not have a secondary school diploma or its recognized equivalent, and have not achieved an equivalent level of education; or are English language learners.

Q: Can we use the funds to help young children from the same family of the adults we are serving?

A: As stated in the application, funds shall not be used for the purpose of supporting or providing programs, services, or activities for individuals who are not eligible individuals as described above, except for such purpose if programs, services, or activities are related to family literacy activities, where it is a requirement to provide interactive literacy activities between parents or family members and their children and to provide an age-appropriate education to prepare children for success in school and life experiences. In providing family literacy activities, an eligible applicant shall attempt to coordinate with programs and services that are not assisted under this grant prior to using funds for adult education and literacy activities awarded through this grant for activities other than those listed above.

Q: Does a student need a green card to qualify as an English language learner?  Can we serve anyone who does not have documentation?

A: As long as those you serve meet the criteria for eligible individuals, they are eligible to be served. As is noted on Page 4 of the application, funds must be used to provide adult education and literacy services to eligible individuals:

• Who have attained 16 years of age;
• Who are not enrolled or required to be enrolled in secondary school under State law; and
• Who:
  • Are basic skills deficient;
  • Do not have a secondary school diploma or its recognized equivalent, and have not achieved an equivalent level of education; or
  • Are English language learners.

Q: Can we serve individuals who already have their High School Equivalency (HSE)? What is basic skills deficient?

A: As is noted in the application, funds must be used to provide adult education and literacy services to eligible individuals:

• Who have attained 16 years of age;
• Who are not enrolled or required to be enrolled in secondary school under State law; and
• Who:
  • Are basic skills deficient;
  • Do not have a secondary school diploma or its recognized equivalent, and have not achieved an equivalent level of education; or
  • Are English language learners.

Basic skills deficient for purposes of this grant means individuals who have skills 12th grade or below, even if they have a high school diploma/equivalency. For example, if an individual who has their high school diploma or high school equivalency needs to take additional courses to get their math skills above a 12th grade level, AEFLA programs are able to serve that individual.

Budget/Fiscal

Q: The AEFLA RFA is now due to CDE on Monday, June 8, 2020 and decisions are anticipated after July.  Given that the fiscal year begins on July 1, 2020, will the 2020-21 AEFLA/IELCE grant awards for the new grant cycle be retroactive to July 1?

A: CDE’s goal is to notify all AEFLA/IELCE applicants of their application status by the end of July 2020, including sending Intent to Award letters at that time. Grant Award Letters, however, will not be issued until September 2020 which allows time for any appeals. The performance period listed on the Grant Award Letter will be July 1, 2020 – June 30, 2021. Please note that any obligation incurred by an eligible applicant during July and August that is determined to be outside of the approved budget and/or does not have an application that is awarded funds may not be reimbursed.  This would mean the eligible applicant may have to pay expenses out of their own ‘general’ funds. 

Q: Please explain the requirement regarding “supplement not supplant.”

A: AEFLA states that Federal adult education funds must supplement and not supplant other state or local public funds expended for adult education and literacy activities. In other words, states cannot withdraw state or local funds they currently are spending for adult education and replace them with Federal dollars.

Q: Most of our current operating funds are federal. Can the 40% match be waived or negotiated?

A: No, it may not. As noted in of the application, federal funds may not be used for matching funds. Matching funds may include both in-kind and cash matches. The matching funds can come from state dollars, local government dollars, private dollars, or in-kind support.

Q: Should budgets be for one year only? 

A: Budgets submitted in the application process should be for one year. This funding opportunity is a multi-year grant with funding for 2020-2021 with opportunity for continuation for three additional years.

Q: In the past, we had been allowed to negotiate admin costs. Will that still be possible?

A: Negotiation of administrative costs is still allowable under WIOA, and CDE/AEI will address that as need be after award.

Q: If administrative costs negotiations (including shared-infrastructure costs) occur after awards are made, can budget revisions occur after that time?

A: Yes, we fully expect revisions will need to be made with regard to shared infrastructure costs, as applicants will submit an estimate in the budget template, given shared infrastructure costs cannot be fully determined until programs have had conversations with partners in the one-stop system within the local workforce areas.

Q: Will negotiations be allowed for admin costs that were previously higher?

A: Negotiation of administrative costs is still allowable under WIOA, and CDE/AEI will address that as need be after award.

Q: Are there any approximate parameters regarding per student costs?

A: No, there are not.

Q: Can we demonstrate shared infrastructure cost via instructional services? Or is it only allowed through admin cost?

A: Shared infrastructure costs are only allowed through administrative costs.

Q: In the past, we have been able to collect program income. Is this still allowable?

A: As described in the application, Colorado has determined that agencies awarded AEFLA, IELCE and/or Corrections Education funds will not be allowed to charge and/or collect program income as a direct result receiving any of the grant funds.

Q: Can students purchase books or is that considered program income?

A: If books are needed to run the AEFLA-funded program, that cost may not be charged to learners being served under the grant. If learners are charged for books, this would be considered program income which is not allowed per page 5 of the RFA.

Q: Can we use AEFLA funding to pay for/offset a testing coordinator salary and/or testing materials since all students are AEFLA-eligible, even though not all students will end up taking an AEFLA class?

A: AEFLA funds may only be used to serve those seeking AEFLA services and that you intend to serve instructionally in AEFLA-funded courses. It would not be appropriate to spend these funds on assessment of or assessment materials for learners who are participants of other programs. It is also important to remember the requirement about supplementing and not supplanting existing services. If testing currently happens for learners that you serve, AEFLA funds should be used to add additional services and not supplant funding currently allocated.

Q: If we budget a percentage of instruction to be paid through AEFLA, do we need to document each individual student's time in class and eligibility? 

A: Any learner associated with the instruction paid for through AEFLA will need to be documented, i.e. assessment, attendance, etc. As a state, we are required to report on all learners seeking services paid for with AEFLA funds.

Q: I'm trying to do my budget for the new grant and I don't know if the LACES funds I'm requesting go under admin or instructional services.

A: LACES is a service the AEI Office pays for for current grantees to meet data and reporting requirements. There will be no cost to programs who are granted AEFLA funds to use the data system for reporting AEFLA-funded learners so there is no need to put LACES related costs in your budget. 

if you are referring to the cost of staff time to meet data entry requirements, that would be categorized as administration cost. 

Q: Can you tell me the percentage of indirect costs, if any, that are allowable under the AEFLA RFP? 

A: The AEFLA grant does allow for indirect costs. Indirect cost are allowable if:

• The documentation from the agency’s cognizant Federal Office approving a restricted indirect cost rate is submitted to Grants Fiscal Management.
• The de minimis rate can be utilized by a non-profit upon review and approval of the Modified Total Direct Cost (MTDC) documentation submitted to Grants Fiscal Management. 2 CFR §200.414 (f)
• The agency can elect to charge administrative costs in lieu of indirect costs upon approval by CDE.

Q: How should staff be entered into the budget worksheet under staff detail?

A: On the budget you are still required to break out salaries and FTE based on the Funding Source:

• Instructional ABE, ASE or ESL
• Administrative ABE, ASE or ESL

An example would be:  A teacher serves ABE and ASE students and is paid 100% with Federal AEFLA funds

LINE ONE:

Funding Source=Federal

Program Type=Instructional ABE

Budget Object=Salary

% of FTE that is directed to these students

Budgeted Amount=the amount covered by the % of FTE

LINE TWO

Funding Source=Federal

Program Type=Instructional ASE

Budget Object=Salary

% of FTE that is directed to these students

Budgeted Amount=the amount covered by the % of FTE

The same would need to be entered for Employee Benefits.

Q: Should we designate a percentage of funding towards English language instruction for those instructors providing those services on the budget?

A: The budget must be reflective of the time and resources spent on each program type (ABE, ASE, ELA, Admin). If a staff’s time or other costs paid for by the AEFLA grant are associated to ELA activities, that should be reflected in the budget.

Q: Are navigator costs allowable personnel costs? If so how are they typed in the budget?

A: Navigator costs are allowable and can be typed under the budget as “instruction”. 

Q: Does Grants Fiscal need the costs of the different agencies within the consortia reflected a particular way in the budget document?

A: The costs in the budget will be reflected differently depending on how the lead agency sets up the consortium

• If the lead agency is going enter into a contract with its consortium members, the budget should reflect Purchased Services with a brief explanation of what is being provided by the member. In this case, costs would be typed as “Other Purchased Services”  OR
• If the lead agency is going to have each member submit a budget to the lead agency and the lead agency will pass through funds to them to cover costs, then you will need to enter the costs by Object – Salary, Benefits, Supplies – with a note as to the associated agency’s name.

Q: If I include indirect costs, does that increase the match amount?

A: You will need to allocate match on the total award which would include indirect. 

Q: What are the definitions for 0300 Purchased Services and 05000 Other Purchased Services?

A: If you go to the Chart of Accounts, the 0300 object code descriptions start on page 126.

Q: For non-profits, is it acceptable to provide links to annual audits? 

A: Yes, it is. 

Q:  May applicants collect program income if they receive AEFLA or IELCE in the new grant cycle?

A: No, program income will not be allowed if applicants are awarded AEFLA, IELCE, and/or Corrections Education funds (see page 5 of RFA).

Q: If program income is not allowed, does that mean you cannot charge for services even if it is a minimal fee?

A: Yes, the RFA states on page 5 that program income will not be allowed if applicants are awarded AEFLA, IELCE, and/or Corrections Educations funds. This includes any fees.

Q: Must at least 50% of the staff paid by AEFLA funds be full time employees?

A: No. There is no requirement in the RFA that says 50% of staff paid with AEFLA funding must be full-time employees. Page 52 of the RFA, in the scoring rubric, states that “Programs which employ over 35% of full-time instructors will receive “bonus points” as noted below.

Q: Is the IELCE budget completed on a different budget than the AEFLA budget?

A: Yes. Applicants applying for IELCE funds must complete the budget template called “IEL Civics 2020-21 Budget.”

Q: Would a corrections application need a separate budget?

A: No. Applicants applying to deliver Correctional Education with the approximate 15% of AEFLA funds anticipated to be awarded for that service will complete either or both the AEFLA 2020-21 Budget template and the IEL Civics 2020-21 Budget template. On those templates, corrections funding must be identified using column P which is labelled “% Directed to Corrections.”

Funding Distribution

Q: What is the allocation process within a region if there is more than one provider/grant application for the area? Will the top grant be given their full amount and the remainder of funds go to the next grant(s) in line? Is it possible that the higher scored grant will not get their full amount in order to allocate to other grant(s) from the region?

A: As this is a competitive grant process, applications will be scored and ranked based on those scores. Our goal in this grant is to have as wide of distribution as possible to serve the largest amount of learners that we can across the state of Colorado. There is no guarantee that submitting an application will result in funding or funding at the requested level.

Q: If providers in a workforce area do not apply or earn the minimum number of points for the application will funds be redistributed across the other applicants?

A: As outlined in the Colorado WIOA State Plan, CDE must fund programs in each federally recognized Local Workforce Development Area, so we will continue efforts for outreach to ensure we receive applications from each area to meet the requirement for representation across the state.

Q: Will there be only one grant awarded per rural counties?

A: Distribution of funds is based on Local Workforce Development Areas, rather than counties. For the Colorado Rural Workforce Consortium, applicants must designate which sub-area(s) they intend to serve. Decisions about the number of applications that will be funded per each Local Workforce Development Area will be based on application scoring and amounts of funds awarded. At this point, because applications have not yet been submitted or scored, we cannot say if there will only be one grant awarded per Local Workforce Development Area.

Q: Can we apply for the full amount of funds listed for their sub-area in the RFA?

A: Yes, grantees can apply for the amount of funds available in their Local Workforce Area or Sub-area.

Q: Can we ask for more funds than the full amount of funds listed for their sub-area in the RFA?

Please refer to the funding formula documentation in Appendix B: Funding Distribution Calculations for Local Workforce Areas* for information about the maximum distributions for each area and sub-area. 

Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) Funding

Q: Do the Local Workforce Development Area distribution percentages apply to the Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding?

A: No, only the Adult Education and Literacy funding (WIOA Sec. 222(a)(1)) is subject to the Local Workforce Development Area distribution percentages.

Q: How deeply can we go in citizenship instruction? Rights, responsibilities, yes. What about the 100 questions?

A: As is noted in the application, the purpose of the Integrated English Literacy and Civics Education program (WIOA Sec. 243(a)) is to:

• Prepare adults who are English language learners for, and place such adults in, unsubsidized employment in in-demand industries and occupations that lead to economic self-sufficiency; and
• Integrate with the local workforce development system and its functions to carry out the activities of the program.

Further, Integrated English Literacy and Civics Education “means education services provided to English language learners who are adults, including professionals with degrees and credentials in their native countries, that enables such adults to achieve competency in the English language and acquire the basic and more advanced skills needed to function effectively as parents, workers, and citizens in the United States.” As long as the proposed program is in alignment with this purpose and definition, it would be allowable.

Q: Are there “standards” for IELCE?

A: Based on the statute, there is a difference between an IELCE activity under Adult Education and Literacy Services (WIOA Sec. 222(a)(1)) funding and an IELCE program under Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding. The IECLE activity under Adult Education and Literacy Services (WIOA Sec. 222(a)(1)) funding requires English Language Acquisition and civics education and may include workforce training.

An IELCE program under Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding must include all of the components of an IELCE activity and an IET, which requires workforce training. 

If you apply for Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding, IET must be provided. As stated in the Clarifying Activities Webinars, the program must be designed to offer IET at any point. Individual learners receiving services under Sec. 243 may not be accessing all of the components of IET, depending on their needs, but the program must be designed for all learners using Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funds to access IET services as soon as the student is ready.

Q: Civics should still be a mandated component in IELCE program instruction?

A: Civics is a mandated component of IELCE Sec. 243 funding. 

Q: Do customers need to be in ESL NRS Levels to be served with these funds?  There is a sequencing gap between ESL to workforce or postsecondary education that CASAS or BEST Plus cannot be used for to determine gains. Not sure how to use these funds effectively unless we are transitioning students to ABE programs or teaching outside of the assessment being used.  Any guidance on this?

A: As learners being served with Title II funds, they will need to be tested per the assessment policy. The program must be designed to offer all the components required under IELCE Sec. 243 concurrently and contextually. Individual learners receiving services under Sec. 243 may not be accessing all of the components of IET, depending on their needs, but the program must be designed for all learners using IELCE (WIOA Sec. 243(a)) funds to access IET services as soon as the student is ready. 

Q: Can IELCE funds be used for facilities as well as instruction as long as it is program space?

A: Yes, the IELCE (WIOA Sec. 243(a)) funds can be used to pay for program space being used by the IELCE program.

Q: What is the amount that may be requested from IELCE?

A: AEI will award approximately $880,000 of the AEFLA funds made available by the federal government to be used specifically to provide Integrated English Literacy and Civics Education (IELCE) in combination with Integrated Education and Training (IET). That amount is not tied to any specific Local Workforce Development Area. Applicants may apply for any amount up to the $880,000 approximate total of IELCE funding that will be awarded. Full details about the IELCE funding can be found on page 5 of the RFA.

Q: Is there a match requirement for the IEL Civics funding?

A: The match requirement for the IELCE budget is the same as the match requirement for the AEFLA budget, which Colorado has set at 40%* as described on page 5 of the RFA.

Integrated Education and Training

Q: If we apply for Integrated English Literacy and Civics Education Program that we do not need to provide Integrated Education and Training (IET), but that it is allowable?

A: Based on the statute, there is a difference between an IELCE activity under Adult Education and Literacy Services (WIOA Sec. 222(a)(1)) funding and an IELCE program under Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding.

The IELCE activity under Adult Education and Literacy Services (WIOA Sec. 222(a)(1)) funding requires English Language Acquisition and civics education and may include workforce training.

An IELCE program under Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding must include all of the components of an IELCE activity and an IET, which requires workforce training. Please reference the Clarifying Activities Webinars for more information.

If you apply for Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funding, IET must be provided. As stated in the Clarifying Activities Webinars, the program must be designed to offer IET at any point. Individual learners receiving services under Sec. 243 may not be accessing all of the components of IET, depending on their needs, but the program must be designed for all learners using Integrated English Literacy and Civics Education Program (WIOA Sec. 243(a)) funds to access IET services as soon as the student is ready.

Q: In order to offer IET (Integrated Education & Training), do you also have to apply for IELCE funding, or can you offer IET through the other funding streams?

A: IET is an allowable activity under AEFLA and a required activity under IELCE.

Q: We are trying to develop our IET programs for the upcoming grant cycle. We are planning to offer 3 total, 2 of which are programs within the our organization. The other is a partnership with a local organization. Do we indicate the per student coverage for each seat we cover for AEFLA students? Or do we have to itemize exactly what we are covering for IETs each cohort? 

A: Applicants will need to itemize the expenses for the IETs, not using a per student cost. For example, the applicant could includes line items for instructional supplies, instructional salary, and intake and orientation, among others.

Shared Infrastructure Costs

Q: What exactly does it mean to "use a portion of funds to maintain one-stop delivery systems"? What types of costs would we be expected to share?

A: WIOA One-stop partners are required to share the infrastructure costs associated with one-stop system operations by using a portion of funds available for program and activities to maintain the one-stop delivery system. Shared infrastructure costs of one-stop centers must come out of administrative costs associated with the AEFLA grant award.

Please reference the “WIOA Wednesday: WIOA One-Stop Infrastructure Funding Part 1” webinar for additional guidance about Shared Infrastructure Costs: 

Q: If we are working with more than one workforce area, do we need to budget infrastructure support for all of them?

A: Yes, shared infrastructure costs are required for each Local Workforce Development Area the applicant intends to serve.

Q: Our service area includes multiple local workforce development areas, and our organization has relationships with all of them to varying degrees. If we partnered with all of them for the AEFLA proposal, would we need to have a higher percentage of costs go to shared infrastructure in order to support all three areas, or could we divide up the specified amount among all 3?

A: If your organization chooses to apply to serve more than one local workforce development area, you would not necessarily need to have a higher percentage of costs applied to shared infrastructure in order to support all three areas. All one-stop partner contributions to the costs of operating and providing services within the one-stop center system must be proportionate to the relative benefit received. Should your organization receive WIOA Title II funding in this competition, you would engage in negotiation with the one-stop partners within each local workforce development area to determine shared infrastructure costs that are proportionate to the relative benefit received in each local workforce development area.

Local Workforce Development Board Review

Q: Should we arrange to have our local workforce development board review our application before turning it in, or does CDE organize that?

A: Applicants should submit applications to CDE. CDE will coordinate Local Workforce Development Board reviews.

Q: Since the adult education representatives on the local workforce development boards will be recused during review of proposals, what are your recommendations for ensuring board members are educated about Title II programs?

A: CDE/AEI will be working with the Colorado Workforce Development Council to provide training to local workforce development boards about the Tool for Local Workforce Development Boards and about adult education, Title II programs.

Q: Are CDE staff planning on doing presentations to local boards on what has been funded before and the specifics of the RFP/ or major changes?

A: Presentations to the Local Workforce Development Boards will be focused on this RFP and on the goals established to meet this grant competition and regarding the Title II connection with the WIOA Colorado State Plan.

Q: Are e-signatures ok on the Local Workforce Development Board Alignment Review document?

A: Yes

Q:  How will the Adult Education representatives ensure that the intent of the RFP is followed?

A:  The MOU and Infrastructure Agreements with the Local Workforce Development Board is intended to align all services and expectations.

Q:  What elements are required in the MOU/Infrastructure agreements?

A:  A breakdown of requirements for this documentation can be found in the Policy Guidance Letter, WIOA-2016-03, Change 1.

Q: Do we need to have our local workforce board approval before submission of the RFA?

A: No, you do not have to have local workforce board approvals in place prior to submitting the RFA. The local workforce boards will review the RFA(s) for the relevant local area after applications are submitted. Please see Attachment A of the RFA for more information about local workforce board review.

Eligibility

Q: These new eligibility requirements will disadvantage programs that have attempted to serve adult learners with the largest barriers to employment, who have a harder time achieving measurable skill gains. This seems counter-intuitive to the goals of WIOA in serving Priority of Service populations. If CDE wished to set this as a new eligibility requirement, why has CDE not communicated this previously with grantees and worked with them to provide the resources they need to help learners achieve MSGs?

A:  As a result of Colorado’s chronic low performance for measurable skills gains for federally-funded Adult Education programs across Colorado, the U.S. Department of Education is requiring Colorado to make changes to our competitive process for the Adult Education and Family Literacy Act (AEFLA) program. As such, the Colorado agency that oversees Adult Education Initiatives (AEI), which is the Colorado Department of Education (CDE), is required to comply with the Federal government’s requirements to raise performance or face sanctions. One of the minimum requirements of Colorado is to only allow prior grantees or applicants who can prove to meet minimum performance standards and indicators. These minimum performance standards are set by the U.S. Department of Education, not Colorado staff.

Per 34 CFR § 463.190(d), sanctions to the state’s grant award are applied for failure to achieve adjusted levels of performance, which occurs when either: (1) Any overall State program score or overall State indicator score falls below 90 percent for the program year, or (2) Any of the States' individual indicator scores fall below 50 percent for the program year. The Measurable Skill Gains indicator target that was negotiated with the U.S. Department of Education for 2019-20 is 37%. In order for Colorado AEFLA programs to meet the current 2019-20 target, the Measurable Skill Gains rate must be at least 90% of 37%, which is 33% (rounded to the nearest whole). Therefore, Colorado set the minimum demonstrated effectiveness target at 33%. Additionally, Additionally, OCTAE has provided technical assistance around demonstrated effectiveness and reviewed Colorado’s RFA. CDE was not able to notify current grantees of the RFA requirements prior to the application being published in order to ensure that all eligible applicants have equal access to information when applying for the grant opportunity.

Colorado anticipates that these higher standards required by the Federal government will increase performance to better serve all adult learners across Colorado, since some of our most significant skills gains are in the lowest quartile of gains, this reflection shows the neediest of those served.

Q: Does AEI realize that many current grantees will be eliminated based on the new eligibility requirements?  

A:  Per 34 CFR § 463.190(d), sanctions to the state’s grant award are applied for failure to achieve adjusted levels of performance, which occurs when either: (1) Any overall State program score or overall State indicator score falls below 90 percent for the program year, or (2) Any of the States' individual indicator scores fall below 50 percent for the program year. The Measurable Skill Gains indicator target that was negotiated with the U.S. Department of Education for 2019-20 is 37%. In order for Colorado AEFLA programs to meet the current 2019-20 target, the Measurable Skill Gains rate must be at least 90% of 37%, which is 33% (rounded to the nearest whole). Therefore, Colorado set the minimum demonstrated effectiveness target at 33%. Additionally, OCTAE has provided technical assistance around demonstrated effectiveness and reviewed Colorado’s RFA.

Grant Application

Q: Does DOC need to complete the entire application?

During the review of the Request for Applications by the Office of Career and Technical Education at the U.S. Department of Education, it was determined that all applicants who are applying for funds, even if only Corrections funds, will need to submit the full application. 

Q: Is the original signature page mailed separately?

A: No, please keep that for your files. You will only submit an electronic version to CDE.

Q: Since we’ve reverted funds to CDE more than once, where do we document that/how do we show that on the cover page of the eligibility confirmation application?

A: You can add additional lines on the cover page to address the years that funds were reverted to CDE.

Q: The application documents reference the Authorized Representative for an agency, is it acceptable if the Authorized Representative is other than the board or organization president?

A: Realizing that there are several different types of eligible applicants that may apply for these funds, it may not be a board that governs the organization applying for funds. For example, for institutions of higher education, the “Board President” is often replaced with the college president for signatory purposes. Typically the authorized representative for CDE means anyone who can sign off on the application and is agreeing to the terms of the application. In many cases, this has to do with a fiscal contact.

Q: Does a MOU need to be turned in with the grant application?

A: As stated on page 3 of the RFP, eligible providers that receive grants under the Adult Education and Family Literacy Act Grant Program will be designated as one-stop partners and are required to align and contribute to the one-stop delivery systems in Local Workforce Development Areas. Specifically, one-stop partners are required to enter into a local memorandum of understanding with the local board, relating to the operation of the system.

An MOU does not need to be turned in, nor will one be accepted when the RFP application is submitted.

Q: If we choose not to apply this year will we have an opportunity to apply next year? 

A: CDE anticipates awarding four-year grants as a result of this competition. 

Q: The application instructions indicate we should use 12-font for the proposal. Is it allowable to use a smaller size font for charts or diagrams?

A: It is fine to use a smaller font for charts and diagrams, however the rest of the narrative itself should be in 12 pt font. 

Q: How does AEI want us to cite our research used for writing the grant? Footnotes or a bibliography? APA or MLA?

A: Footnotes would be best. We don’t specify APA or MLA, whichever you prefer is fine as long as you adhere to the page limit.

Q: Can a completed GED subject count as a post-test?

A: No. GED tests are not an allowable post-test per the Federal Register for  demonstrating educational gain by pre and post-test. However, learners can also demonstrate measurable skill gain by obtaining a high school diploma or its equivalent.

Q: We signed the grant application using a mouse. It is our actual signature, pen just wasn’t used. Is this acceptable?

A: Yes

Q: Can I use AEFLA funds to pay for workforce training?

A: This is allowable if the workforce training is a part of Integrated Education and Training (IET). However, with limited Title II funds, and there being a focus on leveraging funds so that they are used most effectively, programs need to first see if there is workforce training available in the community and if there are funds other than Title II funds available to pay for workforce training. The Integrated Education and Training webinar. located on the prospective grantees page, goes into further detail about options to pay for workforce training.

Q:  Where is the map for the local workforce centers?

A: The program map by local workforce area can be found on AEI’s Find a Program page. 

Q:  Do organizations that operate in multiple Workforce areas have to apply for each individual area?

A:  All applicants will use page 14 of the application to indicate in which local areas they intend to offer services. Applicants will submit just one cover page regardless of whether or not they are applying to serve in just one or multiple Local Workforce Development Areas.

Q:  Can a Federally Recognized Tribe apply for this funding opportunity under “Other” on the application?  

A:  Yes, Federally Recognized Tribes are eligible to apply under the “Other” category.

Q:  What happens if an applicant’s organization is not identified in a “Proposed Adult Ed Svcs by Local Workforce Area/SubArea”?

A:  All counties across the state are located within a Local Workforce Development Area (LWDA).  Please see the map of Local Workforce Development Areas on AEI’s website to identify which LWDA your locations would fall under.

Assurances

Q: Should the program director initial all of the assurances or should the staff member who is delegated to implement the assurance, initial?

A: The staff person responsible for implementing the assurances (e.g. Accessible Design Coordinator, LACES System Administrator, Assessment Coordinator, etc.) should initial the assurances. Both that staff person and the program director should sign the assurance. 

Q: How does a program judge academic progress for a learner?

A: AEI allows grantees to determine inability to make progress for their programs, but it is often measured by using approved assessments. 

Q: What is the timeline for progress evaluation?

A: AEI allows grantees to determine the timeline for progress for their programs. To do so a program might consider the amount of time for pre- and post assessments as long as the time determined meets or exceeds the standard outlined in the Colorado Assessment Policy. 

Q: Why must all individuals paid under the grant be required to have professional learning requirements?

A:. Grantees are expected to engage in the establishment and operation of high-quality, research-based professional learning programs focused on the improvement of local instructional practices and services. Each administrative role will have a training, online courses, webinars, and other training opportunities. The focus of these professional learning requirements is to provide all grantee staff with the relevant level of WIOA Title II knowledge to effectively implement their roles, in addition to establishing and fostering leadership pathways for adult educators. 

Q: How do we gain access to the  WIOA E-Learning system for our teachers?   What do we need to do for the WIOA Grant?

A: After grantees are approved for funding, they will receive access to the WIOA E-Learning system (Moodle). There are a variety of courses in place, including those for Adult Basic Education Authorization, as well as other courses.  

Q: Do the ABE instructors have to have an ABEA or LIA authorization to be paid out of this grant?

A: Per the ABEA Policy, AEFLA-funded programs must: 

• Ensure all instructors who work with AEFLA-funded learners be authorized within three years of their date of hire; 

• Have at least one authorized instructor on staff at all times; 

• Programs that have not received AEFLA funding in the past will work with AEI staff to ensure compliance with this requirement. 

• Establish and keep a local compliance plan with progress updates on file at the program for each instructor teaching courses in which AEFLA-reported learners are enrolled and who do not have the authorization.

Q: The local attendance assurance states that a short-term learner must be offered a total of 100 hours in a term.  Do summer sessions count as a term?

A: Terms will be defined by each applicant in the Class List Template. In column L, applicants will list the start and end date for every managed enrollment cohort for each class. In column O and Q, applicants will list the total number of weeks and attendance hours being made available in each term. In column T, applicants will indicate if a summer term continues into future program years. Any term in the Class List offering 10 or fewer weeks of classes must offer at least 100 instructional hours in the term. Any term in the Class list offering 11 or more weeks of classes must offer at least 120 hours in the term. Full details about class hour requirements can be found on page 35, Attendance Assurances, and page 53, scoring rubric, of the RFA. 

Q: Do the assurances pages not count in the 17-page limit?

A: Correct. The required Assurances do not count in Narrative page limits listed on page 18 of the RFA.

Other

Q: How do we access the webinars?

A: On the Prospective Grantees page, click on the Adult Education and Family Literacy Act Federal Grant Application PDF. The links for the webinars are listed on page 9, under Eligibility and Technical Assistance.  

Q: Do you need to register for the webinars?

A: No, you do not need to register for the webinars. At the correct time, click on the link provided on page 9, under the Eligibility and Technical Assistance section, in the Adult Education and Family Literacy Act Federal Grant Application PDF.

Q: Where can we access the webinar recordings?  

A: The eligibility confirmation webinar recording can be found here. The application webinar recording can be found here.

Q: Can an eligible provider submit an AEFLA grant application and be named as a vendor of transferable career training courses in another AEFLA grant?

A: Yes, your organization could submit an AEFLA grant application and be included in narrative for another organization’s application as a vendor of transferable career training courses.

Q: Are colleges required to provide the same programs across all campuses in their service area?  And if not, can an AEFLA provider incorporate services to two different regions in one application?

A: Decisions about which campuses/sites to offer programs are local decisions.

Q: What is HSE?

A: HSE is high school equivalency. In Colorado, this includes GED, HiSET, and TASC.

Q: What is the expectation around "family-centered approaches and services"? Does this only apply to family literacy?

A: Family-centered approaches and services is a priority area for this funding opportunity, and we leave decisions to local providers regarding how you best meet the priority for family-centered approaches in your collaborative efforts with other agencies and organizations within the local area. This does not only apply to family literacy.

Q: Are letters of support required or accepted for this proposal?

A: No, letters of support are not required and will not be accepted for this proposal.

Q: Do you give specifics on implementation of technology?

A: CDE leaves decisions about implementation of technology for local programs. Applicants can decide how they will integrate technology in their classrooms. The Workforce Innovation and Opportunity Act (WIOA) does have focus on connection with workforce and digital literacy, so CDE encourages applicants to be creative in how they will integrate technology into instruction.

Q: How will participant identities be protected in view of possible future federal infringement on rights of individual participants?

A: Any information in your application should not include personally identifiable information, as far as your participants go. You may speak to your participants, but we are not asking that you disclose participant information, i.e. specifics names, in this application. Further, the RFA has language regarding data and privacy and ensuring that you are not disclosing personally identifiable information in your application.

Q: Do you encourage programs from multiple workforce regions to collaborate to share costs like training and professional development if they are proposing implementing similar models?

A: This is a local decision. Our goal is to leverage dollars to be able to serve more learners across Colorado. We are inviting eligible providers to submit applications that have innovative solutions to be able to serve more learners across the state.

Q: If several Adult Education programs apply together through a consortium model, but their service delivery methods are diverse because of their different student populations/needs, where and how should that be described in the grant application?

A: Should you consider applying as a consortium, it is recommended that you identify which areas of service make the most sense to report as associated with each point within the rubric. Reviewers will be looking at the applications as a single application to provide the comprehensive services. As is noted in the RFA, applications must identify one agency that will act as the lead agency for the consortium. The lead agency shall submit a single proposal on behalf of the consortium that outlines a plan to provide adult education and literacy activities throughout the local workforce development area, explaining the roles and responsibilities of each member agency.

Q: Does a location need to be in the actual workforce region to apply for those funds? I ask as we have locations that are situated in one workforce region, but anticipate by data collected that most customers will be coming from other workforce regions. Can a location request funds to serve more than one region from a single location? Or any other configuration where the county and the region may not align with those being served?

A: In order to apply for funds for the local workforce development area, an applicant needs to have programming offered within the boundaries of that area. An applicant is welcome to have additional relationships that are beneficial for students who may be served by a local workforce development area outside of that in which the adult education provider is located, but the adult education provider would not be considered a one-stop partner in the local workforce development area unless the organization offers services within those boundaries. It is important to note that as an adult education provider, applicants may serve any/all learners who show interest in attending their classes, regardless of where other WIOA title services may be provided. Title II eligibility does not require a learner to reside or work within the area served in order to make use of adult education services in that area.

In the application, the applicant should only state the number of learners they project to serve at sites located within each local workforce development area. Should an applicant have sites in more than one local workforce area, the applicant will need to state the number of learners projected to serve at each site based on the local workforce development areas.

Q: Could you give us an example of research-based methods? 

A: We cannot give examples of research-based methods, but the purpose of this requirement is to ensure methods being employed at the program are based in research.

Q: Isn’t it a requirement of the AEFLA grant that we report on employment outcomes for learners? Will we need to track that information at the program level to meet reporting requirements?

A: The Adult Education Initiatives Office obtains employment outcome information at the state level through a data match. Programs do not need to track this information at the program-level for state or federal reporting purposes. The statewide database utilized by AEFLA grantees does have functionality for programs to track outcomes and goals of learners if they wish to for their own purposes but that data is not used for federal reporting purposes.

Q: Does a state junior college need to submit proof of non-profit status and evidence of financial stability?

A: No, they do not.  

Q: How do I access Labor Market Information (LMI) data?

A: LMI data is provided in local plans.

Q: Is there a place to see previous grantee performance?

A: Measurable Skills Gains by grantee can be found in the Performance Accountability. 

Q: If we don't meet the MSG targets for the year, will our funds be cut off for the next year?

A: Page 4 of the RFA states, “Funding in subsequent years for grantees is contingent upon continued federal appropriations and upon grantees meeting all grant, fiscal and reporting requirements.” The AEI Office will be providing awarded grantees additional information about required performance targets and subsequent year funding after those targets have been determined by OCTAE, which has not yet occurred. At this time, applicants should prepare for an MSG target of at least 37%.

Q: In our non-AEFLA funded jail program we often can't get 40 hours to post-test, but we have many HSE graduates. How much would post-test rate affect us if we can meet MSG rates?

A: Because performance targets for 2020-2021 have not yet been finalized by OCTAE, we are not able to answer at this time if not meeting the post-testing rate requirement while meeting the MSG rate requirement will have an impact on grantees. Once those targets are set, our office will be able to provide more information.

Q: Will a student getting their actual HSE Diploma count as an MSG gain?

A: Yes, HSE Diploma attainment, if it occurs within the program year, has always been counted as a gain, if unduplicated from pre- and post-test level completion gains and post-secondary entrance gains. MSGs are measured on NRS Table 4. HSE Diploma attainment is collected through an end-of-year data match with DiplomaSender.

Q: If we choose a program like IDEA, does CDE approve of their hours to competency formulas?

A: Distance learning platform requests must be submitted to CDE before being approved to offer distance learning under the AEFLA grant. That request must include a description of how the distance learning platform measures attendance hours. If the platform does not use a clock time to measure attendance hours, but instead uses mastery (as determined by an assessment or through grading) to assign attendance hours based on work completed, the methodology for determining mastery of each lesson or unit as well as the total attendance hours awarded if mastered per lesson or unit must be included in the request. Full details about distance learning platform requests can be found on pages 46-48, Distance Learning Assurances, of the RFA.

For more information

Adult Education and Family Literacy Act Federal Grant - Request for Funding Opportunity Web Page