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Directive:

DINAP BULLETIN 89-19


Status: Cancelled

Subject:
Allocation of Travel Costs to Appropriate Cost Categories

Purpose:
To provide grantees with a clarification of the regulations concerning the allocation of travel costs to appropriate cost categories.

To

All Native American Grantees

From

HERBERT FELLMAN PAUL A. MAYRAND Chief Director Division of Indian and Office of Special Targeted Native American Programs Programs

Date

January 17, 1990

Expiration Date

Continuing.

Rescissions:    None.
Text :
Reference. 20 CFR 632.3,B Clarification. a. Staff-Training. According to 20 CFR 632.36 (d) staff training is an administrative expense. Therefore, all costs, including travel costs, associated with providing training to grantee staff must be charged to the administration cost category. Such costs cannot be charged to the training cost category as a "training assistance" cost. The only exception to this rule is discussed below. b. Training Provided to Staff who will Train Participants. The cost of specialized training received by a staff member(s) to enable his/her to provide such vocational training to a participant (a) (e.g. typing, data processing, auto mechanics) is to be charged to the classroom training cost category, including any travel coats associated with such staff training. c. Staff Travel Costs Associated with Provision of Training Assistance. The cost of staff travel associated with the provision of training assistance to participants may be charged to the training coat category only if its purpose fits the definition given at 20 CFR 632.78 (d). To meet this definition, such travel must be conducted on behalf of a specific participant or group of participants, e.g., a Job developer traveling to a nearby town to attempt to find Jobs for recent classroom training graduates; a counselor traveling to a distant part of the reservation to provide counseling to a participant in danger of dropping out of the program; or a staff member traveling to a distant point in the service area to give participants an orientation to the 'World of Work' and job search assistance. Travel coats associated with the provision of training assistance and chargeable to the training cost category would be primarily of a local, non-overnight nature and would involve the use of a personally owned vehicle or a tribal vehicle. The cost of staff travel undertaken to negotiate a specific OJT contract(&) for a specific participant(s) may be charged to the training cost category, where the cost of travel to speak at an employers' meeting to explain the operation and benefits of the grantee's OJT program must be charged to the administration cost category. The cost of staff travel which enables a participant(s) to participate in programs under the Act as specified at 20 CFR 632.38 (k)(4) must be charged to the supportive services cost category. Examples of this would be where a staff member transports participants to and/or from a training or work site to which they would otherwise be unable to go because of a lack of transportation facilities. Also, the cost of sending a staff member to a remote corner of the service area to take applications from people who cannot got to the central office would also be chargeable to the supportive services cost category. d. Travel Costs Associated with Regional or National Grantee Meetings. The cost of staff (counselors, job developers, etc.) for the purpose of attending regional or national meetings to improve their skills is not to be charged to the training (i.e., training assistance) coat category. It is considered 'staff training" as specified at 20 CFR 632.38 (d) and must be charged to the administration cost category. The cost of any grantee staff to attend any national or regional meeting as specified at 20 CFR 632.38 (d) and (k)(2) must be charged to the administration cost category. e. Travel Costs of Participants who Serve in Staff Positions. All allowable participant travel costs must be charged to the supportive services cost category except in those instances where a participant (e.g. a CSE participant) is actually functioning as a program staff member. In such cases, travel costs would be charged to the appropriate cost category following the guidelines for permanent staff members set forth above. Action. If a grantee is in doubt as to the proper way to allocate a particular travel cost, a written request for guidance is to be sent to the Chief of the Division of Indian and Native American Programs immediately. Inquiries. Call your DINAP Federal Representative.

Attachments :
None.




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