Washington

States must identify AEFLA allowable activities, consistent with WIOA title II, in its grant materials.  Specifically, the term “adult education and literacy activities” means programs, activities, and services that include adult education, literacy, workplace adult education and literacy activities, family literacy activities, English language acquisition activities, integrated English literacy and civics education, workforce preparation activities, or integrated education and training.  SBCTC did not include a correct list of these allowable activities in its PY 2022 grant application.  SBCTC must ensure accurate language for the definition of adult education and literacy activities, found in section 203(2) of WIOA, is included in future grant applications. 

States may award up to 20 percent of the basic education awards (section 231) to local providers for corrections education programs.  To do this, States must provide clear instructions in their application materials that applicants may request funding for corrections education activities solely, or in combination with, other AEFLA activities.  Furthermore, States must require applicants to specify the allowable activities and budgets for corrections education.  States must also prepare award notifications which identify the amount awarded for corrections education separately from other AEFLA activities.  Finally, States must annually report outcomes for adults in correction education programs on Table 10.  States may conduct a single competition or may conduct a separate competition to award funds for corrections activities.  

In the PY 2022 grant application, SBCTC did not identify corrections educations activities as an area of focus, nor did it require budgets for corrections education.  When interviewed, State staff were not aware that local providers were engaged in corrections education despite reporting corrections education expenditures.  After the monitoring review, State staff interviewed each of the local providers that reported institutionalized expenditures and determined that these local providers were engaged in corrections education.

States are required to allow local providers to charge indirect costs as part of administrative costs.  AEFLA is a program where federal funding is intended to "supplement and not supplant" other State or local funding; therefore, local providers must use a negotiated restricted indirect cost rate if they choose to charge indirect costs.  SBCTC incorrectly set indirect costs at five percent for all subrecipients, which does not comply with the Uniform Guidance or EDGAR.  Specifically, in the grant award notification terms and conditions SBCTC states, “to calculate the indirect/F&A amount, take the salary and wages from each budget activity and multiply that amount by 5%.  This is the maximum amount that can be budgeted for indirect/F&A.”  SBCTC must revise and issue policy guidance to inform local providers about the allowability of charging indirect costs, using a restricted rate.

When a State adds a requirement based on a State rule or policy that is not imposed under federal law or regulation, it must identify the rule or policy as being imposed by the State.  In the PY 2022 grant application, SBCTC included several State-specific requirements in the grant application but did not clearly and consistently identify them as such.  SBCTC must revise its application materials to clearly and consistently identify State-imposed requirements that are based on the State’s rules or policies.

GEPA requires local applicants, in their applications to the State for funding, to provide a description of how the local applicant will ensure equitable access to, and participation in, its federally-assisted program for students, teachers, and other program beneficiaries with special needs.  In SBCTC’s PY 2022 competition, the State agency did not require local applicants to provide a statement describing how they would meet GEPA requirements in their applications.  In SBCTC’s PY 2027 competition, the State agency must include a requirement that local applicants include a description of how they plan to meet the GEPA requirements and explain that the State will review the statements to determine if they are sufficient.

States are required to provide notification to subrecipients of AEFLA awards with specific information in the notification.  SBCTC did not provide each AEFLA subrecipient with a letter of an award notification and grant document which included the terms and conditions of receiving federal funds.  SBCTC must include all the requirements of a pass-through entity with their grant documents for PY 2022 continuation awards and subsequent AEFLA awards.

States must consider how applicants respond to the 13 considerations as described in section 231(e) of WIOA prior to awarding AEFLA funds.  In the PY 2022 application, SBCTC included the 13 considerations in their application materials.  However, several considerations were paraphrased and lost the intent of the statutory requirement.  As a result, the federal review team had difficulty determining how reviewers used several of the considerations, as some of the application questions and scoring criteria did not clearly indicate to applicants and reviewers that they should be considering all the information in the 13 considerations as part of the competition process.  In SBCTC’s PY 2027 competition, the State agency must ensure that the State’s request for proposals clearly states the 13 considerations, how they will be applied in the review process, and that the reviewers take into account all of the 13 considerations in reviewing and scoring the applications.

States must identify activities considered for local administrative costs consistent with AEFLA.   SBCTC did not include in its PY 2022 application materials a correct list of these activities.  SBCTC must ensure accurate language for activities using administrative funds, found in section 233(a)(2) of WIOA, is included in future grant materials for both continuation awards and competitions.