DRA webinar details Work (ETA-2408) grant: eligibility, allowable uses and June 20 application deadline

Molly Chamberlain of Chamberlain Dunn LLC summarized the U.S. Department of Labor’s FOA ETA-2408 (Work, round 6) in a DRA webinar, describing who may apply, who may be served, allowable uses of funds and administrative requirements for applicants.

The Work initiative is intended “to create economic mobility, address historic inequities for marginalized communities of color, rural areas, and other underserved and underrepresented communities,” Chamberlain said, and to connect workers in Appalachian, Delta and Northern border regions to stable, family-sustaining jobs. The DRA region covers 252 counties and parishes across parts of Alabama, Arkansas, Illinois, Kentucky, Louisiana, Mississippi, Missouri and Tennessee, she said.

Who can apply and who can be served: Chamberlain said eligible applicants include government entities (state, county, city or township), special districts, Indian tribal governments, state or local workforce development boards, state or local education agencies and independent school districts, labor organizations, labor-management partnerships, institutions of higher education (public, private, Hispanic-serving, Historically Black Colleges and Universities and tribally controlled institutions), public and Indian housing authorities, and nonprofits (with or without 501(c)(3) status). “DOL will not advise on whether you are eligible,” Chamberlain said; applicants must determine their own eligibility and are advised to review pages 6–7 of the FOA.

Participant categories and equity priorities: Work funds may serve three participant groups — new entrants, dislocated workers and incumbent workers — but participants must live or work in the NVRC, ARC or DRA region. Chamberlain defined new entrants as people entering the workforce for the first time or returning after a long absence (examples include formerly incarcerated individuals and long-term unemployed); dislocated workers are those terminated, laid off or formerly self-employed and now unemployed (applicants should consult the WIOA legal definition in the FOA); incumbent workers are employed people who need training to retain or advance in their jobs. Applicants must prioritize historically marginalized populations (for example, women, people of color, justice-involved individuals, people with disabilities, veterans and limited-English-proficiency individuals) and be deliberate when narrowing their defined service population because the Department will hold grantees to the scope they propose.

Allowable activities: Chamberlain outlined five main categories of allowable activities: training and other employment-related activities (including registered apprenticeships, on-the-job training, internships and classroom/virtual training), participant support services (transportation, childcare, counseling, assistance with tools or certifications and emergency assistance), employer services (technical assistance to improve job quality, recovery-friendly workplace programs, peer coaching and subsidies for apprentices/interns), strategic planning, and equipment purchases/renovations. She noted a separate funding-restriction item allows limited participant incentives later in the FOA.

Limits and requirements on capital and planning costs: Strategic planning is allowable but “may not exceed either $100,000 or 50% of the grant award, whichever is less,” Chamberlain said, and must support sustainable employment outcomes with measurable benchmarks. Capital expenditures (equipment purchases and renovations) are permitted only if they directly facilitate employment and training needs, must comply with uniform administrative requirements and cost principles at 2 CFR part 200 and DOL supplemental requirements at 2 CFR part 2900, and require prior written ETA approval through a modification if awarded. New construction and property acquisition are not permitted. Chamberlain said equipment/renovation budget lines cannot exceed $100,000 or 50% of the budget and projects proposing capital expenditures are expected to serve at least one participant during implementation.

Incentives, indirect costs and prohibited spending: The FOA allows budgeting up to 1.5% of total grant funds for participant incentives (for example, gift cards) to compensate participants for time spent reporting outcomes that cannot be sourced from administrative records; grantees must have policies and procedures for such incentives. Applicants may include indirect costs via a negotiated indirect cost rate, cost allocation plan, or can use the 10% de minimis rate of modified total direct costs if they do not have a negotiated rate. Chamberlain also highlighted non-allowable costs cited in the FOA, including food, profit and excessive salaries or bonuses.

Partnership and application requirements: Applicants must include partnerships representing three types: at least two employer industry partners; the public workforce system (for example, state or local workforce development boards or American Job Center operators); and at least one organization representing the target community to ensure local input. For each partner, applicants must provide partner names, location, role, planned activities, and evidence of commitment (letters of support, memoranda of understanding or similar documentation).

Registration and deadline: Chamberlain emphasized that applicants and subrecipients must be registered with SAM.gov and have a UEI (a 12-character alphanumeric identifier) and must also be registered on grants.gov; SAM registration is free and can take up to 10 business days. Grants must be submitted through grants.gov; Chamberlain reminded listeners to start UEI, SAM and grants.gov processes early. The application deadline is Thursday, June 20, 2024 at 11:59 p.m. Eastern, and technical questions should be sent to the email provided (mc@chamberlaindunn.com). “You must make that determination” about organizational eligibility, Chamberlain said.

What applicants should do next: Begin SAM and grants.gov registration immediately, assemble required partner documentation and ensure proposed activities and budgets conform to the FOA caps and reporting expectations. Chamberlain offered to answer technical questions via the contact shown in the webinar.