DRAFT Waiver Request: Administrative Cost Arrangements

Waiver Request:  Administrative Cost Arrangements

Required Elements:

In satisfaction of the required elements identified in the U.S. Department of Labor (DOL) Waiver Request Tool:

1. The statutory and regulatory requirements are identified below, within the waiver request.

1. There are no State or local barriers, only Federal barriers imposed by WIOA and its final rules.

1. These waiver requests will help fulfill the State and Federal goals of effective and efficient use of public funds in the administration of the WIOA-governed one-stop delivery system in Iowa.

1. The State anticipates that this will help program outcomes by creating administrative efficiencies not otherwise available, which will, in turn, free up limited WIOA funds for use in other areas to meet Federal requirements.

1. This waiver request will help local areas, including Local Workforce Development Boards (WDBs), by allowing them to combine their efforts and resources relating to administrative functions, which will allow them to find cost efficiencies that would otherwise be unavailable.

1. IWD will continue to conduct monitoring of local areas and Local WDBs, including their compliance with all WIOA requirements governing administrative costs. IWD will collect and include information about waiver outcomes in the State’s WIOA annual report.

1. IWD posted a draft of this waiver request on the State’s public comment portal for 30 days prior to submitting this waiver request.

Waiver Request:

Under WIOA section 106, the State must develop policies and procedures for the designation of regions. If the State designates a planning region, WIOA section 106(c) the Local Workforce Development Boards (WDBs) and chief elected officials (CEOs) in the planning region must engage in a regional planning process that results in the establishment of administrative cost arrangements, including the pooling of funds for administrative costs, as appropriate, for the region. Iowa’s community colleges are invaluable partners in the State’s workforce development system. Many serve not just as training providers but also as career services providers for WIOA Title I Youth, Adult, and Dislocated Worker programs. In consulting with stakeholders, including Iowa’s community colleges, Iowa Workforce Development (IWD) believes that the planning region requirements under WIOA section 106 and 20 CFR section 679.510 are too burdensome. Local areas should be able to establish administrative cost arrangements without being part of a planning region and being forced to engage in the other elements of the regional planning process.

Allowing local areas to establish administrative cost arrangements even if they are not part of a planning region will allow them to save money on administrative costs. For example, instead of the Local WDBs in two local areas each hiring a director and spending $120,000 combine on directors, two Local WDBs could establish an administrative cost arrangement that allows them to share a director and spend only $60,000. Moreover, instead of the Local WDBs in two local areas each having a $10,000 operating budget that combines to equal $20,000, the two Local WDBs could establish an administrative cost arrangement that allows them to spend just $10,000.

IWD asks that the Secretary waive the WIOA requirement that establishing administrative cost arrangements between two or more local areas must be part of the regional planning process for designated planning regions under WIOA section 106 and 20 CFR section 679.510. This will allow local areas to find efficiencies in administrative costs without having to jump through the hoops of regional planning.