Well, when playing in the sandbox, you must play by the rules - share, be fair, communicate, be respectful and, most importantly, be honest. As time winds down towards the January 1, 2018 deadline, all American Job Centers (AJCs) must have their Infrastructure Funding Agreement (IFA) portion of the Memorandum of Understanding (MOU) in place. This means the SCSEP community must be ready to play in the sandbox as a required partner.
As we all know, the Training and Employment Guidance Letter (TEGL) 17-16 is your guide to working with your local AJC partner. After reading this TEGL, I know many of your heads were spinning. Certainly, TEGLs are necessary to drive the work of AJC partners. TEGL 17-16 offers concrete guidance so AJCs and the partners are fully aware of what is expected in the development and implementation of an IFA. Some SCSEP grantees may have had good experiences with negotiating their agreements while others may not have been successful or may not even have gotten started. With that said, did you know there are FAQs that serve as a quick reference addressing commonly asked questions and summarizing the key points of TEGL 17-16?
It’s time to jump in the sandbox and understand your responsibilities as described in TEGL 17-16. First, let’s look at the MOU and the IFA to make sure we understand what is expected. The Local Workforce Development Board and AJC partners must enter into a MOU that aligns with the requirements of the Workforce Innovation and Opportunity Act (WIOA). The deadline for executing an MOU was July 1, 2017. Therefore, the IFA must be outlined in the MOU and meet the requirements in TEGL 17-16. The key is to digest TEGL 17-16 because it outlines specific required elements that must be contained in the IFA.
Elements of the IFA - The period of time in which the IFA is effective; identification of the infrastructure costs budget (part of the AJC budget); identification of all AJC partners; description of the review/modification process; steps the group will take to reach a consensus; how IFA-related issues will be resolved when a consensus can’t be reached.
You may be asking – What will this cost me? Here is a brief description of the infrastructure cost and the types of contributions SCSEP partners can make to the IFA.
Infrastructure Cost - What is it and how must we contribute? Infrastructure costs are non-personnel costs that are necessary for the general operation of the AJC such as rent and computers. Non-personnel costs are those that are not compensation for personnel costs. The types of costs that are allowed are through cash, non-cash and third party in-kind contributions.
Cash - Cash contributions can be identified as payments towards rent, utilities, assistive technology equipment, signage, and even office supplies. Just remember, it must be those components that support the general operation of the AJC. Cash is by far the most common way for AJC partners to make infrastructure contributions. Going this route will certainly make your life easier!
Non-Cash Contributions - Non-cash contributions are expenditures acquired by partners on behalf of the AJC, and goods/services such as janitorial services, printing, or even consulting and contracting service can be contributed by a partner program and used by the AJC. Hmm, so what does this really mean? It means to make sure partners agree on the sources/companies that will be used to assess/appraise the fair market value or fair rental value of non-cash contributions. Making sure all the partners are on the same page will save a lot of headaches in the end.
Third-Party In-Kind Contributions - Third-party in-kind contributions are made by a third party and include space, equipment, technology, non-personnel services, or other areas to support the infrastructure costs associated with AJC operations. There are two types of third-party in-kind contributions: 1. General contributions to AJC operations. This type is not made on the behalf of any individual AJC partner. 2. Contributions made specifically on behalf of an AJC partner program.
This is just the tip of the iceberg when it comes to IFAs in your local area. However, in order to play in the sandbox, you must know the rules of engagement and what role you play. If you have successfully worked out your MOU with ease, we want to hear from you. And, if you are still struggling with understanding the process and trying to identify funds to contribute, we want to hear from you too. We also encourage you to contact your peers and ask about what strategies worked for them. As a friendly reminder, don’t forget to register for the webinar on December 6th “MOU Negotiations: The Partner Perspective” on WorkforceGPS.
Remember, you too have the power and voice in creating a mutually beneficial IFA!
Check out these resources: