WIOA Time and Cost Allocation Guide
Document Time and Review Cost Allocation
Classification depends on the work performed, funding source, and award terms. Use this guide to frame questions for your grant and fiscal teams.
Understanding WIOA Time and Cost Allocation
Uniform Guidance and WIOA cost principles inform how staff time is documented and allocated; review current award terms before charging costs.
Potential Program Time
May be allocable to program costs when documented and permitted by the award.
Potential Administrative Time
Some WIOA awards limit administrative costs; check the specific award terms.
Costs Requiring Review
Review the applicable award terms and cost principles before charging an activity.
Governing Rules and Regulations
Key regulatory frameworks to consult when reviewing WIOA cost classifications.
Primary Regulations
- 2 CFR Part 200 (Uniform Guidance)
Defines allowable costs, cost allocation, and documentation requirements for federal grants.
- 20 CFR 683.215
Distinguishes administrative vs program costs for WIOA Title I.
Award Guidance
- Grant and state instructions
Review the specific award agreement and current agency guidance for applicable cost limits.
- 2 CFR Part 2900
DOL-specific grant requirements.
Staff Time and Cost Categories
Examples for discussion, not a determination that any particular expense is allowable under a specific award.
A. Potential Program Activities
Activities that directly support participant outcomes.
- Case management & eligibility determination
- Developing Individual Employment Plans
- Career services & job placement
- Training coordination (OJT, apprenticeship)
- Supportive service coordination
- Employer engagement for placements
- Tracking skill gains & credentials
B. Potential Administrative Activities
Administrative cost limits depend on the WIOA title, allocation, and award terms; review before charging costs.
- Accounting, budgeting, payroll
- Procurement & property management
- Audit resolution & monitoring
- General legal services
- Policy development
- Centralized IT & HR support
C. Activities Requiring Special Cost Review
Some activities are generally unallowable; check the applicable cost principles and exceptions.
- Lobbying activities
- Fundraising
- Entertainment expenses
- Fines and penalties
- Charges without a documented allocation
- Costs outside an award’s scope
Staff Activity Review Matrix
Review examples against your award terms and accounting policies before classifying time.
| Task Category | Cost Classification to Review | Relevant Guidance |
|---|---|---|
| Eligibility determination and case management | Review as potential program cost | 20 CFR 683.215(a); 20 CFR 680.150 |
| Individual employment planning and career services | Review as potential program cost | 20 CFR 683.215(a); 20 CFR 680.170 |
| Employer engagement and training coordination | Review as potential program cost | 20 CFR 683.215(a); applicable award terms |
| Participant progress and supportive services | Review as potential program cost | 20 CFR 683.215(a); 20 CFR 680.900 |
| Financial reporting, payroll, and procurement | Review as potential administrative cost | 20 CFR 683.215(b); applicable award terms |
| General HR, IT, and policy development | Review as potential administrative cost | 20 CFR 683.215(b); applicable award terms |
| Lobbying activities | Generally unallowable; review exceptions | 2 CFR 200.450 |
| Fundraising and entertainment | Generally unallowable; review exceptions | 2 CFR 200.438; 2 CFR 200.421 |
Documentation Requirements
Keep records sufficient to support the actual work and applicable cost allocation.
Personnel Activity Records
Keep records that accurately reflect the work performed and support the allocation of salary and wage costs.
Cost Allocation Plans
Document how shared costs are allocated across the benefiting funding sources.
Activity Linkage Records
Keep evidence connecting charged time to the relevant award and activity.
Keep program activity and cost allocation distinct
Apprentage organizes apprenticeship worksite and learning records. A sponsor's grant and fiscal teams remain responsible for documenting staff time, applying cost principles, and determining whether an expense may be charged to a particular award.
Questions about apprenticeship program records?
Discuss how Apprentage organizes OJT and RTI evidence for sponsor and intermediary teams.