Submission DateComments
07-20-2022 11:09:141. There is a need to establish defined, annual budget review periods when anticipated expenditures will be looked at/discussed with the local board.
2. Define what documentation will be required to justify obligations for boards delivering direct services.
3. Establish procedures to manage end-of-year clawback if expenditures should drop in final months of the PY resulting in more than 20% rollover by closeout.
07-20-2022 08:20:40I caution DEO/CSF in the implementation of this waiver. Unspent/unobligated funds does NOT equate to un-needed funds.

Local Boards have strategic business plans in place that may include approaches to policy implementation with deliberate rationale to have funds unobligated until specific, strategic times. The definition of obligation is very narrow, and therefore having unspent/unobligated money does not mean there is not a plan to spend the money. (For example, Summer Youth programs where the money isn't spent until the last month of the program year. These funds are included in the Board's budget but don't meet the criteria of an 'obligation' and therefore the funds could be taken away).

In this local area, our board has intentionally, thoughtfully, and purposefully only spent the prior year WIOA grant (so in 2022-23 PY, we are expending 2021-22 PY WIOA grants), so they can respond with necessary injections of services when our local area experiences economic downturns or disasters...or, a more timely example, if the Board ceases operation and needs to go through a close out process, there are dollars to continue to support participants currently engaged so they can complete their programs, and operations can strategically and rationally close.

Additionally, those LWDB's with ITA waivers may obligate funds at a slower rate. Another consequence of shifting dollars from a Board is reducing the ability of those Boards losing funds to meet the spending percentage thresholds programs have in place (WIOA ITA expenditures, Youth WEX expenditures, etc), because when budgeted dollars go away, percentages fluctuate--not to mention shifts in overhead/pooled costs.

This waiver could, in essence, take away decision making at the local level and may force a small region to not offer services it has strategically planned for.
07-11-2022 22:33:08MTC graduate this program saved me and my children from homeless while I attended practical nursing full time M-Friday. I wish this program will continue to help others as it did for me and many others.