-2 REGIONAL FIELD INSTRUCTION CETA NO. 120-75 2. Policy. (continued) a. Attachment A of FMC 74-4 states: "Any cost allocable to a particular grant or cost objective under the principles provided for in this circular may not be shifted to other Federal grant programs to overcome fund deficiencies, avoid restrictions imposed by law or grant agreements, or for other reasons. The attachment also indicates that costs must "not be allocable to or included as a cost of any other federally financed program in either the current or a prior period." b. Based on specific legislative requirements, CETA Regulations specify different participant eligibility criteria for each title and separate reporting requirements for each title. Also, the cost of the acquisition of or rental or lease of administrative supplies, equipment, materials, and real property is not allowable for the administration of PSE programs. c. Under the provisions of CETA and the implementing regulations as well as the requirements of FIC 74-4, funds provided to prine sponsors under one title of CETA may not be used to support costs of a different title. d. With the confusion that has existed concerning the allocation of costs between titles, the Employment and Training Administration will not disallow costs which are incurred during the present grant period where prime sponsors have established arrangements in an approved grant agreement which do not conform to the requirements stated in paragraphs a., b., and c. above. e. With the beginning of the next grant period (October 1, 1976), specific allocation arrangements should be made to conform to the above requirements. The allocation process can be accomplished in several ways; it is important that a reasonable means of allocating administrative costs to the benefiting program be adopted. f. The first step in any cost allocation system should be to insure that all costs which can be directly assigned to a program activity or title are so assigned. This, includes administrative costs. For example, if an office is rented for administration of the supplemental Summer program, that rent should be directly assigned to the Summer program. 8. After all direct costs are assigned, a "pool" of unassigned administrative cost will remain. These casts can be allocated to titles in several ways, including the following: (1) Time Distribution. Adinistrative staff time attributable to the various titles can be kept with unassigned costs allocated to titles based on the pro rata share of reported time. -3 REGIONAL FIELD INSTRUCTION CETA NO. 120-75 (continued) (2) Grant Funding. Each title can be assigned "pool" costs based on its relative share of the total grant. (3) Work Distribution. A count of work or output factors can be maintained (e.g., number of enrollees, number of contracts) by title and unassigned costs allocated on the basis of percentages generated by these work counts. 4. Action. a. Prime sponsors should be guided by the policy outlined above. b. Prime sponsors should develop an appropriate allocation system prior to submission of the Fiscal Year 1977 grant application. Additional guidance as to cost allocation methods is being developed in the Employment and Training Administration national office and will be made available in the near future. Lewell Whitsiit J. TERRELL WHITSITT RESCISSIONS: None ATTACHMENTS: None (3 MGEC-PD&E) I have been informed by the president of the Georgia Hospital Association that you are having a hearing on February 12, 1976, to discuss a proposed law giving congress oversight powers on administrative regulations. I will not be able to attend the hearing, but I would like to express my concern about such legislation. I believe strongly that there should be a sharp distinction between executive responsibilities and legislative responsibilities and therefore prefer that congress continue to grant the executive branch the responsibility of writing without harassment, the regulations for approved legislation. Perhaps congress needs to be more specific in its authorship of legislation and certainly if the regulations do not fulfill the legislation's intentions, the corrective action should be taken, but hopefully congress will not become too meddlesome in the responsibilities of the executive branch of our govern I am writing at the suggestion of your Atlanta office to give my comments related to your bill on federal regulations and their effect on local operations. As a community-based mental health center, we operate under a maze of local, state, and federal regulations and guidelines. My immediate concern has to do with HEW regulations for Title XX programs. The new Title XX regulations, related to determining eligibility, are an immense obstacle to the delivery of services in that they are entirely too time-consuming, require documentation that often cannot readily be provided, and require a breach of confidentiality when it is necessary to contact an employer to obtain documentation. The regulations as presently formulated are degrading, repressive, and counter to establishing a positive helping relationship in the delivery of services. Certainly there could be regulations establishing eligibility on the basis of a person providing necessary information and signing under the penalty of perjury that the information is true and correct to the best of his knowledge. I will appreciate your adding my remarks to your hearing record and sending me any response you wish to make. Thank you very much for your kind letter of February 9 inviting me to I an enclosing several publications of our Center for the Study of Best wishes. Sincerely, Murray L. Weidenbaum MLW: ew Enclosures |