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 CategoryCost Classification to ReviewRelevant Guidance
Eligibility determination and case managementReview as potential program cost20 CFR 683.215(a); 20 CFR 680.150
Individual employment planning and career servicesReview as potential program cost20 CFR 683.215(a); 20 CFR 680.170
Employer engagement and training coordinationReview as potential program cost20 CFR 683.215(a); applicable award terms
Participant progress and supportive servicesReview as potential program cost20 CFR 683.215(a); 20 CFR 680.900
Financial reporting, payroll, and procurementReview as potential administrative cost20 CFR 683.215(b); applicable award terms
General HR, IT, and policy developmentReview as potential administrative cost20 CFR 683.215(b); applicable award terms
Lobbying activitiesGenerally unallowable; review exceptions2 CFR 200.450
Fundraising and entertainmentGenerally unallowable; review exceptions2 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.