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Questions and Answers:
Faith-Based / Community-Based Organizations
Grant Solicitations

• Questions and Answers Relating to FBO/CBO Solicitations

• Three System-Building Competitions to Expand Customer Access and Build Capacity of CBOs/FBOs to Participate in the One-Stop Delivery

• TEGL 17-01: Incorporating and Utilizing Grassroots, Community-Based Organizations, Including Faith-Based Organizations, in Workforce Activities and Programs

Questions and Answers Relating to FBO/CBO Solicitations

The Department of Labor has provided responses to questions about the three recently published SGAs (seeking proposals to increase the participation of faith-based and community-based organizations in the One-Stop system) submitted by prospective applicants under SGA/DFA 02-106 (grants for States), SGA/DFA 02-107 (grants for intermediaries), and SGA 02-108 (grants for small organizations).

Potential applicants are once again urged to read the SGA thoroughly to make their determination on submission and content. A number of questions that have been received are similar in nature. ETA has attempted to develop a response which addresses similar issues and concerns. You may, therefore, not find your specifically-worded original question, but you should be able to locate a response to address your issue.

Because of the system-building partnerships and linkages under these three solicitations, ETA encourages all applicants to read the entire set of questions and answers. For example, a question submitted by a potential intermediary under SGA/DFA 02-107 may carry implications for an applicant seeking funding under SGA/DFA 02-108 because of the prospective sub-grant relationship. ETA has, however, developed a index of responses which are:

For applicants under SGA/DFA 02-107, ETA recommends reading of Questions and Answers: 1 *10 14-21, 23-29, 31, 33-34.

For applicants under SGA/DFA 02-108, ETA recommends reading of Questions and Answers: 1, 2, 5, 8-10, 12-34.

1. What does the Department consider to be a "service area" under this SGA?

The applicant is responsible for defining the "service area" to be covered. The intent of this solicitation is to engage intermediaries whose coverage and customer service reach extends across several local communities. Therefore, a service area could be an entire state, several counties, a regional labor market area covering portions of more than one state, or another geographic configuration.

2. Do the local affiliates of an established Intermediary organization constitute its grass-roots network for the purposes of this solicitation?

No. As stated in the SGA, for the purposes of this announcement, local affiliates of national organizations are not considered "grassroots" and would not be eligible for a sub-grant award.

3. Can a One-Stop operator apply for an intermediary grant?

No. Intermediaries would be third-party entities responsible for connecting community- and faith-based organizations to the One-Stop system. Therefore, it would not be appropriate for the operator of a One-Stop center to serve in that capacity.

4. Can a local council of governments or public library be considered a community-based organization for the purposes of this solicitation?

For purposes of this solicitation, a local council of government or a public library can only apply if it meets the standard established in the SGA. As stated in the SGA, under this competition, eligible "intermediaries" are defined as those non-profit community and/or faith-based organizations with connections to grassroots faith-based and community organizations with the ability to connect those organizations to the nation's workforce development system in more than one service area.

5. Would a faith-based subcontractor be allowed to provide 4 weeks of work experience and pay a minimum wage stipend to participants for their work?

Funds awarded under this solicitation are intended to be "system-building" investments. It is expected that grant funds will be used to make connections between the One-Stop system and local faith and community-based organizations. Therefore, the payment of stipends and provision of work experience activities would not be appropriate uses of funds under this initiative.

6. What is the maximum amount of dollars that can be requested by an Intermediary applicant?

With a reservation of $5.0 million for this competition, the Department expects to award between 5 and 8 grants, ranging between $500,000 and $1,000,000. The ETA grant officer will determine the final number of awards and dollar amounts.

7. Is the funding under the intermediary solicitation (SGA/DFA 02-107) related to the funding under the State solicitation (SGA/DFA 02-106) and or the funding under the grass-roots organization solicitation (SGA/DFA -2-10 )?

No. The award under one solicitation will be independent of the award under either (or both) of the other solicitations. If a State elects not to apply under SGA/DFA 02-106, the Department would still encourage intermediaries and/or small grass-roots organizations to apply for these system-building grants.

8. My organization is interested in applying for these grant resources? How do I get in contact with my State workforce development officials?

The Department provides a listing of principals in State and local workforce development. Your organization is encouraged to visit http://usworkforce.org/asp/contacts.asp for access to these directories.

9. Will this grant be offered in subsequent years? Will there be future year funding to support the Department's investment in this initiative?

There is no assurance that there will be funding for this initiative in future years.

10. Please clarify for what year (FY 2002 or FY 2003) the agency's social services budget has to be under $300,000.

The cost limitation applies to the current budget year (FY 2002).

11. We are an intermediary organization. If we secure supplemental funding to help us meet the solicitation's objectives, where do we reflect these resources?

The supplemental funding should be reflected in the narrative and/or a separate budget attachment. The Department encourages the identification and leveraging of other funds to support system-building.

12. How much, if any, of the funds awarded to an individual grantee under SGA-02-108 can be used to cover the costs of salaries?

There is no specified limit on the amount of grant funds that may be used to pay the costs of salaries for awards made under SGA-02-108. The only cost limitation indicated in the SGA is a 10% limitation on administrative costs pursuant to 20 CFR 667.210(b). The grant officer may approve additional administrative costs when adequate documentation is provided by the applicant. However, the maximum amount of administrative costs that may be authorized is not to exceed 15% of the total amount of the award. Salaries may be classified as either program or administrative costs dependent upon the function(s) that staff are performing. Guidance on the functions and activities that are to be classified as administrative costs is provided at 20 CFR 667.220(b) and (c).

13 We are a 501(c)(3), not for profit faith based social service organization. Our organization consists of more than six staff. We separate our staff, however, by "cost centers." Can we apply for the funding as a single "cost center" that would be managing the grant?

No. The size of your organization does exceed the staff limit (6 individuals) which is contained in the solicitation. The fragmentation by cost center does not meet the spirit and intent of this solicitation - i.e., the expanded participation of small grass-roots organizations. (Please also see response #2.) You are certainly encouraged to partner with the existing One-Stop system in your local area or State.

14. Please clarify the definition of an eligible grassroots organization in these solicitations.

As noted in the solicitation, the Community-based or Faith-based grassroots organization must be headquartered locally, and must have either: a) 6 or fewer employees total or b) a social services budget of $300,000 or less, independent of other budget line items such as salaries and expenses. The eligible grassroots organization can define in the application the geographic area for which it proposes to provide services. The Department is looking to broaden the participation of small organizations in the nation's workforce development system, and introduce "first-time" working relationships between these organizations and the agencies which serve our jobseekers and employers. (Please also see responses #2 and #13.)

15. Do you have any examples of successful FBO/CBO involvement in the One-Stop shops?

Yes, there are many examples of successful collaborations of the workforce development system and community-based and faith-based organizations. The Department has elected not to cite them by name to avoid giving a competitive advantage to any entity by naming it.

16. What are core services under WIA?

Core services include determination of eligibility for WIA programs; outreach, intake and orientation; initial assessment of individual; job search and placement assistance; career counseling; and provision of employment statistics, performance and cost information on training providers, and information on local area results on WIA performance measures. Core services also include provision of information on supportive services, information on filing unemployment insurance claims, assistance in establishing eligibility for Welfare-to-Work and financial aid, and follow-up services (for 12 months after placement).

17. What is training under WIA?

Under WIA, eligible adults and dislocated workers receive training services which may include occupational skills training; on-the-job training; skills upgrading; entrepreneurial training; job readiness training; adult education and literacy activities; and, customized training for employers who commit to hiring trained individuals. Eligibility requirements are outlined in the WIA regulations at 20 CFR Part 663.

18. What special services are available to youth under WIA?

Eligible youth may receive tutoring, study skills training and dropout prevention activities; alternative secondary school offerings; summer employment opportunities; paid and unpaid work experience; occupational skills training; leadership development opportunities; supportive services; adult mentoring; 12 months of follow-up services; and comprehensive guidance and counseling.

19. Our work with the One-Stop has focused on micro enterprise owners and linking them with training, and access to capital. Would this element, either by itself or in relationship to other activities, be eligible for funding under SGA/DFA 01-108?

These resources are not intended to replace or supplant existing efforts that are focused on system-building. The Department does support micro-enterprise development, and views self-employment assistance as an effective workforce development strategy. The applicant should demonstrate that these resources will build upon, rather than supplant, efforts now underway to benefit the community.

20. SGA/DFA 02-107 contains the Establishment Clause of the First Amenment of the United States Constitution. As a small grass-roots organization, we noticed that this language does not appear in SGA/DFA 02-108. Does this language apply?

Yes. This Clause does apply to SGA/DFA 02-108. The Department will be publishing this clarification as an amendment to the SGA in the FEDERAL REGISTER within the next week.

"The Establishment Clause of the First Amendment of the United States Constitution prohibits the government from directly funding religious activity. These grants may not be used for instruction in religion or sacred literature, worship, prayer, proselytizing or other inherently religious practices. The services provided under these grants must be secular and non-ideological. Grant or sub-grant recipients, therefore, may not and will not be defined by reference to religion. Neutral, secular criteria that neither favor nor disfavor religion must be employed in their selection. In addition, under the WIA and DOL regulations implementing the Workforce Investment Act, a recipient may not employ or train a participant in sectarian activities, or permit participants to construct, operate, or maintain any part of a facility that is primarily used or devoted to sectarian instruction or worship. Under WIA, no individual shall be excluded from participation in, denied the benefits of, subjected to discrimination under, or denied employment in the administration of or in connection with, any such program or activity because of race, color, religion, sex (except as otherwise permitted under title IX of the Education Amendments of 1972), national origin, age, disability, or political affiliation or belief."

21. Where can we find technical assistance for the grant?

Upon grant award, the Department will outline its technical assistance strategies to the recipients. Several technical assistance and outreach products which support this grant-making initiative have already been developed (or are underway). These are available at www.usworkforce.org and www.dol.gov/cfbci/outreach_materials.htm

22. Is $25,000 the maximum for this project?

Yes

23. Is there a matching requirement?

No

24. When Filing in Standard Form 424 (revised 4-88) question number 9 "Name of Federal Agency" do I answer "Department of Labor - Employment & Training Administration?

Yes

25. Does the Executive Summary need to be double-spaced or single-spaced?

The Executive Summary may be single-spaced. The narrative application itself should be double-spaced.

26. Will advance payments be available for the intermediary and for the organizations that receive sub-grants from the intermediary?

No.

27. Please advise what items in an organization's budget should and should not be included as part of its "social service budget" in determining whether that budget is within the $300,000 maximum. Specially, should we include as part of our social services budget the salaries of case managers, employment readiness workshop leaders, and after-school program staff, all of whom provide client services?

For a non-profit organization operating a Title V Senior Community Service Employment Program (SCSEP), are the Title V enrollee wages considered part of the $300,000 or less social services budget or part of "other portions of the budget such as salaries and expenses" that are not included in the $300,000 or less social services budget?

All costs related to provision of social services (including salaries and expenses) should be included. If the organization conducts additional activities (e.g. runs a small business), these would not be included in the calculation. (Please see response to Question #14.)

28. For a non-profit organization operating a Title V Senior Community Service Employment Program (SCSEP), are the Title V enrollees counted as part of the six or fewer full-time equivalent employees?

No.

29. Are you looking for total agency social services budget or project budget? Our agency has several contracts working with TANF recipients and our social services budget is greater than $300,000 however, it is strictly for TANF clients. Our social services budget under this award would be much less than $300,000.

The eligibility requirement refers to the applicant's total social services budget, not the project budget. (Please also see response to Question #13.)

30. How do you keep these administrative costs under 10% with an average administrative limitation of $2500? Is there any cost sharing or matching requirements for the grant?

The Department encourages the identification and leverging of other funds to support system-building. (Please also see responses to Question #12.)

31. How do I find Code of Federal Regulations at 20CFR 667.210 (b)?

The Code of Federal Regulations is a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the Federal Government. It should be available in most comprehensive libraries and is available on-line at http://www.access.gpo.gov/nara/cfr. "20" refers to Volume 20 of the Code and section 667.210(b) can be found in part 667, which provides WIA administrative rules. 20CFR 667.210 is a reference to the provision in the final regulations for implementation of the Workforce Investment Act. These regulations were published in the Federal Register on August 11, 2000. A link to a copy of this document appears below. These regulations can be found on-line at www.usworkforce.org/finalrule.txt. For your convenience, we have cited the regulation below:

Sec. 667.210 What administrative cost limits apply to Workforce Investment Act title I grants?

(a) Formula grants to States:

(1) As part of the 15 percent that a State may reserve for Statewide activities, the State may spend up to five percent (5%) of the amount allotted under sections 127(b)(1), 132(b)(1) and 132(b)(2) of the Act for the administrative costs of Statewide workforce investment activities.

(2) Local area expenditures for administrative purposes under WIA formula grants are limited to no more than ten percent (10%) of the amount allocated to the local area under sections 128(b) and 133(b) of the Act.

(3) Neither the five percent (5%) of the amount allotted that may be reserved for Statewide administrative costs nor the ten percent (10%) of the amount allotted that may be reserved for local administrative costs needs to be allocated back to the individual funding streams.

(b) Limits on administrative costs for programs operated under subtitle D of title I will be identified in the grant or contract award document.

(c) In a One-Stop environment, administrative costs borne by other sources of funds, such as the Wagner-Peyser Act, are not included in the administrative cost limit calculation. Each program's administrative activities area chargeable to its own grant and subject to its own administrative cost limitations.

We would also encourage applicants to review the "Preamble" to these regulations at Federal Register/ Volume 65, No. 156 page 49293 for additional background and context.

(Please also see the response to Question #12.)

32. For SGA 02-108, are there any restrictions on the income of clients to be served? Are there any age or other restrictions on clients served by the partner CBO/FBO agencies using these grant funds (such as 14-21, high risk, dropout, etc)?

No.

33. Could you please provide me with an example of an "intermediary" applicant? I would like to find out the meaning of "Intermediaries" as it applies to these solicitations.

As noted in the response to Question #15, the Department will not cite examples by name to avoid giving a competitive advantage to any organization. Please review the definition of an "intermediary" for this SGA and decide if you qualify and want to apply: For purposes of this competition, ``intermediaries'' are defined as those non-profit, community, and/or faith-based organizations with connections to grassroots faith-based and community organizations with the ability to connect those organizations to the nation's workforce development system in more than one service area. The eligible intermediary does not have to be located in more than one jurisdiction as long as their reach extends beyond one jurisdiction, and the application addresses providing services in more than one jurisdiction.

34. Does an intermediary have to be one agency or can it be a consortium of organizations?

There is no prohibition against consortia of intermediaries applying under the SGA. The consortium, however, must follow the "Application Process" contained in the SGA. The Department recognizes that a consortium may reflect stronger partnerships and linkages in the community which our system-building is attempting to encourage.

35. What is meant by the term "constituent members"? Is it a listing of the Board of Directors for the proposed Intermediary that is being requested, or a listing of key staff members, or what? Are we allowed to pre-select these groups as sub-grantees, since we have high confidence that they will be results-producers, and simply report who they are in our grant proposal? Or would we be expected to operate some kind of open bidding competition after we were awarded the DOL funding that would lead to the selection of sub-grantee organizations?

The Department views a "constituent member" as a grass-roots organization which is included in the intermediary's formal or informal network. Your strategy for including subgrantee organizations must recognize that our intention is to bring new grassroots organizations into the workforce development system. These grant funds are not intended to supplant funding for existing workforce development activities. With respect to the questions, therefore, your organization will determine the administrative approach and protocols to take to meet the requirements and objectives of the SGA.

36. Does the DOL expect that the sub-grantee organizations will reflect diverse religious affiliations, or can the intermediary select subgrantees based on their probability of achieving the objective (of increased service delivery, increased connections between One Stops and FBO, etc.) regardless of their religious affiliation?

DOL expects subgrantees to provide appropriate services and be able to achieve the objectives outlined in the intermediary application irrespective of whether the subgrantee is a faith-based or secular community-based organization.

37. Can one agency apply for both the intermediary and faith-based/community-based grants?

An organization can apply for any grant for which it is an eligible applicant. The Department is targeting three separate types of organizations with defined histories and capabilities - States, intermediaries with "geographic reach" and grant management experience, and small grass-roots organizations with limited experience in grant management. Potential applicants should define their "best fit" in responding to these SGAs. It would appear unlikely that any one organization could qualify as more than one type, but it is not prohibited.

38. Can there be multiple submissions from a single organization?.

As the above response (#37) indicates, each SGA has a clear target audience.

39. Are American Indian tribal governments eligible for grants advertised. Is there a separate notice for states and tribes?

Tribal governments are not eligible to apply under the State SGA/DFA 02-106. Tribal governments can apply under the other two SGAs if they satisfy the applicant eligibility criteria. Tribal governments can also be included in a consortium (please see response to Question # 34.

40. May the funding from the grant reimburse our agency for what we are already doing -- primarily the "soft?skills" training with existing staff?

No. The response to question #19 documents the need for "maintenance of effort" in ongoing activities conducted by the intermediary. These grant funds cannot be used to replace or supplant existing resources.

41. Can an intermediary use a small portion of the grant funds to build capacity of a community based employment program operated by the intermediary?

See the responses to questions #19 and #40.

ETA Announces Three System-Building Competitions to Expand Customer Access and Build Capacity of CBOs/FBOs to Participate in the One-Stop Delivery

A total of $9.9 million has been reserved for States; a total of $5.0 million for intermediaries (non-profit, community, and/or faith-based organizations with connections to grassroots faith-based and community organizations with the ability to connect those organizations to the nation's workforce development system in more than one service area); and, a total of $500,000 has been reserved for small non-profit organizations.

SGA/DFA 02-106
* Grants for States - Federal Register (text)
* Grants for States - Federal Register (pdf)
The closing date for receipt of applications is Thursday, May 16, 2002.

SGA/DFA 02-107
* Grants for Intermediaries - Federal Register (text)
* Grants for Intermediaries - Federal Register (pdf)
The closing date for receipt of applications is Friday, May 17, 2002.

SGA/DFA 02-108
* Grants for Small Faith-Based and Community-Based Non-Profit Organizations - Federal Register (text)
* Grants for Small Faith-Based and Community-Based Non-Profit Organizations - Federal Register (pdf)
The closing date for receipt of applications is Monday, May 20, 2002.

* Correction (SGA/DFA 02-108): text correction - Federal Register (text)
* Correction (SGA/DFA 02-108): text correction - Federal Register (pdf)

* Amendment (SGA/DFA 02-108): Establishment clause of First Amendment and use of grant funds- Federal Register (text)
* Amendment (SGA/DFA 02-108): Establishment clause of First Amendment and use of grant funds - Federal Register (pdf)

TEGL 17-01: Incorporating and Utilizing Grassroots, Community-Based Organizations, Including Faith-Based Organizations, in Workforce Activities and Programs

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