4.16.1 Overview
Effective Date: January 1, 2023; Compliance will be evaluated beginning with PY2023 funding allocations
The Workforce Innovation and Opportunity Act (WIOA) is designed to help job seekers and workers, particularly those with barriers to employment, enter and/or advance in the labor market.1 WIOA also serves to match employers with the skilled workers they need to compete in the global economy.2 These purposes are accomplished through the provision of career, training, and supportive services to Adult and Dislocated Worker Program participants, and the provision of the 14 program elements to Youth Program participants.
The purpose of this expenditure goal is to ensure that a reasonable amount of WIOA funding is spent on direct-to-participant costs, including, but not limited to, training-related expenses and supportive services. Providing ample financial supports will serve to improve participant outcomes and overall program success.
4.16.2 Requirements for the 35% Expenditure Goal
Effective Date: January 1, 2023; Compliance will be evaluated beginning with PY2023 funding allocations
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-to-participant costs. 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:
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.
4.16.3 Reporting Requirements
Effective Date: January 1, 2023; Compliance will be evaluated beginning with PY2023 funding allocations
Local WDBs shall maintain accounting records to accurately identify and account for the 35% direct-to-participant costs expenditures. WDBs must report the costs they count toward the 35% expenditure goal monthly in the Contract Management and Expenditure Tracking (COMET) System as memo activities. These costs should be reported in COMET at the time they are incurred.
NOTE: A participant does not have to complete the related service for the associated costs to count toward the goal.
To evaluate achievement of this goal, the amounts reported in COMET will be compared to total program expenditures over the life of each grant (e.g., the PY21 Adult and Dislocated Worker formula allocations). In the event that funds are transferred between programs, the 35% goal will be evaluated against the modified grant amounts.
4.16.4 Monitoring Implications
Effective Date: January 1, 2023; Compliance will be evaluated beginning with PY2023 funding allocations
As this is a goal, and not a requirement, DWD-DET will not apply sanctions to local WDBs that do not meet the goal. However, the local WDB's progress toward achieving the goal will be evaluated during DWD-DET's annual coordinated monitoring. In cases where the goal is not met, or satisfactory progress toward achieving the goal in a given program year is not realized, DWD-DET will identify this as an area of concern. The local WDB will be asked to provide an explanation of the factors impacting spending on direct cost services and any actions taken to increase spending. DWD-DET may require that WDBs and their service providers participate in mandatory technical assistance to identify and/or develop strategies to increase spending on direct-to-participant costs.