Sneak Preview: ETA Addresses 2024 UG Revisions Implementation
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Department of Labor (DOL) Employment and Training Administration (ETA) recently issued guidance to state workforce agencies (SWAs), along with all other ETA award recipients and subrecipients, about the agency’s implementation of the 2024 revisions to Title 2 of the Code of Federal Regulations (C.F.R.), including the uniform guidance (2 C.F.R. Part 200).
DOL originally adopted the Office of Management and Budget’s (OMB) uniform guidance in December 2014, and maintains certain DOL-specific rules for grants administration at 2 C.F.R. Part 2900. In light of OMB’s April 2024 revisions to the Title 2 and the uniform guidance, DOL has updated its grant terms and conditions to conform to the changes, and will apply these to awards going forward.
Recipients and subrecipients receiving new federal financial assistance awards or modifications to existing awards will now follow the 2024 revisions to the uniform guidance, which became effective Oct. 1. Amendments to other parts within subtitle A of Title 2 of the Code of Federal Regulations also now apply to these awards (see “2024 Revised Uniform Guidance Becomes Effective for New Awards,” November 2024). In addition, ETA updated its new terms and conditions to be consistent with the 2024 revisions for grants awarded in September 2024 that have a period of performance beginning on or after Oct. 1. ETA recipients with awards made before Oct. 1, with a period of performance beginning prior to Oct. 1, will continue to follow the 2020 version of the uniform guidance.
Of particular interest to ETA program grantees, the guidance notes that the Workforce Innovation and Opportunity Act (WIOA) (Pub. L. 113-128) authorizes ETA to provide WIOA Youth funds annually to SWAs from appropriated funds that become available every April 1. WIOA Adult and Dislocated Worker programs are funded from two separate appropriations. The first appropriation for the programs is available every July 1 (this portion is commonly referred to as “base” funds) and the second appropriation for the programs becomes available every Oct. 1 (i.e., this portion is commonly referred to as “advance” funds because they are provided in the appropriations act passed during the fiscal year immediately before the fiscal year when the funds become available).
To clarify, funds for program year (PY) 2024 that are available on Oct. 1, 2024, were appropriated during federal fiscal year (FY) 2024, but not made available until October, which is in FY 2025, and are called the FY 2025 “advance” funds.
(The full version of this story has now been made available to all for a limited time here.)
Join us for our following Thompson Grants event:
Federal Grants Forum: Navigating the 2024 Uniform Guidance Changes | Oct. 29-30, 2024 | Virtual Event
Thompson Grants Workshop: Subrecipient Monitoring |Nov. 13, 2024 | Virtual Event
