(A) "Local area" means the subrecipient as
designated by the governor responsible for administering workforce
investment
development activities as defined by department of
labor (DOL) federal regulations. For the purposes of this rule, "
WIOA stand alone local areas" are defined as local
workforce development agencies (WDA)
areas that receive only DOL funding from ODJFS to
administer workforce development services. This rule provides guidelines to
assist
WIA
WIOA stand alone areas in the tracking of time spent
on all direct workforce development services and activities for the purpose of
appropriately allocating costs to the benefiting programs.
Combined WDAs
local areas allocate staff costs in accordance with
rule
5101:9-7-20
of the Administrative Code.
(B) Local areas performing solely
workforce investment
WIOA administrative functions
If a stand alone local area's operations are limited to the
performance or coordination of functions classified as general administrative
functions as listed in this paragraph, the stand alone area shall report all
costs associated with the stand alone area as direct charges to
workforce investment
WIOA administration.
(1) These functions include the following:
(a) Accounting, budgeting, financial and cash
management functions.
(b)
Procurement and purchasing functions.
(c) Property management functions.
(d) Personnel management functions.
(e) Payroll functions.
(f) Coordinating the resolution of findings
arising from audits, reviews, investigations and incident reports.
(g) Audit functions.
(h) General legal services
functions.
(i) Developing systems
and procedures, including information systems, required for these
administrative functions.
(j)
Fiscal agent responsibilities.
(j)
(k)
Performing oversight and monitoring responsibilities related to
workforce investment
WIOA administrative functions.
(2) Staff shall complete a certification
documenting that they work solely on
workforce
investment
WIOA administration functions.
(a) Certifications shall be completed every
six months, in January and July.
(b) Certifications shall be signed by the
employee or a supervisor having firsthand knowledge of the work performed by
the employee.
(c) The stand alone
area shall maintain the certifications at the local level.
(C) Local areas
performing both
workforce investment
WIOA administrative and program functions
A stand alone local area that performs any functions not
covered in paragraph (B) of this rule may develop a cost allocation plan, such
as the ones outlined in paragraphs (D) and (E) of this rule, and in accordance
with 2 C.F.R. 200, or may track time spent on all activities (including
administration) using random moment sampling (RMS). If a stand alone local area
chooses to use RMS, the executive director and all staff in that local area
shall participate in RMS. This requirement is an exception to rule
5101:9-7-20
of the Administrative Code, which states administrative positions are generally
excluded from the time study.
(1)
Stand alone local areas allocating costs by RMS shall track time spent on all
activities using the workforce random moment sample (WFRMS). The WFRMS is
designed to identify activities directly related to program functions
benefiting one or more
workforce
investment
WIOA programs (e.g., adult,
youth, dislocated worker) or the administration of those programs. This
information will not be reported to ODJFS but will be used to allocate costs
for the stand alone area and documentation will be maintained to support those
costs.
(2) Stand alone local areas
shall follow the established WFRMS process for completing the time study. The
stand alone local area shall use the results of the RMS to allocate their costs
by completing the following steps:
(a) Enter
the names of the RMS participants in the RMS roster. The system will generate
the appropriate sample.
(b) Staff
participating in the RMS will complete observation forms in accordance with
rule
5101:9-7-20
of the Administrative Code.
(c) The
stand alone local areas will enter results in the RMS system.
(d) Stand alone local areas are not required
to report this information to ODJFS.
(3) Stand alone local areas shall use the RMS
statistics produced by the RMS system to allocate the costs incurred by the
stand alone area.
(D)
Exception for special grants
A stand alone local area that receives a grant for a specific
program activity may exercise the option to direct charge the costs associated
with that grant, including costs of a staff member who works solely on that
activity. The exception shall be reserved for when a stand alone local area's
usual chosen method of allocation would not appropriately allocate costs (or
distribute expenditures) in accordance with relative benefits received.
(1) Cost associated with that staff member
shall be removed from the other costs of the local area.
(2) Staff shall complete a certification
documenting that they work solely on a specific program or special grant or
workforce investment
WIOA administration functions associated only with a
specific program or special grant.
(a)
Certifications shall be completed every six months, in January and July, unless
the certification can be completed through normal payroll coding and time and
attendance certifications associated with normal payroll activities.
(b) Certifications shall be signed by the
employee or a supervisor having firsthand knowledge of the work performed by
the employee.
(c) Certifications
shall be maintained for auditing purposes.
(3) Stand alone local areas may allocate the
costs associated with the employee working on a special grant directly to the
special grant.
(E)
Activity report exception
A stand alone local area that performs more than one activity
and performs those activities for long periods of time may choose to identify
effort spent on multiple activities or programs by the completion of personnel
activity reports.
(1) Activity reports
are an actual accounting of work performed and not an estimate of work that is
expected to be performed.
(a) Staff shall
complete activity reports after the fact and must reflect actual activities
performed.
(b) Staff shall complete
the report for the total time for which they are compensated.
(c) Staff shall prepare the activity reports
at least monthly, to coincide with a pay period.
(d) Staff completing the activity report
shall sign the completed activity report.
(2) Stand alone local areas shall use the
results of the completed activity reports to allocate the costs incurred by the
stand alone local area.
(F) Documentation supporting the allocation
of costs in a stand alone local area shall not be submitted to ODJFS but shall
be maintained by the stand alone local areas for auditing purposes.
(G) Allocated expenditures shall be submitted
to the county finance information system (CFIS) and shall continue to be
reported as described in rule
5101:9-7-29
of the Administrative Code.
(H)
Financial, programmatic, statistical, recipient records, and supporting
documents shall be retained by the local area in accordance with rule
5101:9-9-21
of the Administrative Code.
