4.16 35 Percent Expenditure Training Goal for Program Year Formula Allocations | 4.16.2 Requirements for the 35% Expenditure Goal

4.16.2 Requirements for the 35% Expenditure Goal

Effective Date: July 1, 2022

Local Workforce Development Boards (WDBs) should spend at least 35% of their annual formula program funding allotment¹ for each of the Adult, Dislocated Worker, and Youth programs on direct cost services. Meeting this goal will ensure that program resources are focused on successfully preparing participants to enter and/or advance in the workforce. This will also allow participants to access the financial supports necessary for them to participate in program services and activities reasonably and successfully without incurring debt.

WDBs may include in the direct cost services calculation all expenditures paid directly to, or on behalf of, a participant, such as:

• tuition and other training-related costs,
• supportive service costs, including needs-related payments,
• youth incentive payments, and
• costs for career services and youth program elements paid directly to, or on behalf of, a participant, such as wages for work experiences² and/or transitional jobs, costs related to an out-of-area job search, or costs associated with relocation.

The 35 percent expenditure goal is calculated using only programmatic funding. Neither the numerator nor the denominator of this calculation includes administrative costs.

Programmatic costs that fund staff wages and benefits for the coordination of such services³ shall not be included in the numerator of this calculation.

• ¹ This does not include administrative funds.
• ² This differs from the expenses allowable when calculating the 20 percent expenditure requirement for youth work experience, which allows the inclusion of staff costs for certain work experience related activities.
• ³ DWD-DET considers such activities to be "case management" and does not consider "case management" to be a direct participant cost.

Direct Costs

Effective date: July 26, 2019

Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. DWD-DET interprets this definition to include training services, support services, and certain individualized career services where funding is provided directly to, or on behalf of, the participant. This excludes basic career services and costs associated with staff time.

2 CFR § 200.413(a)