American Rescue Plan Good Jobs Challenge – Pre-Award Frequently Asked Questions

Updated February 1, 2022

Contents

1. Introduction and Key Definitions

1. What is the Good Jobs Challenge?
2. What is a “sectoral partnership” and a “regional workforce training system”?
3. Are regional workforce training systems the same as Workforce Innovation and Opportunity Act (WIOA) systems?
4. What is a “System Lead Entity” and a “Backbone Organization”?
5. What is a quality job or a good-paying job?
6. What is the difference between jobs created, jobs retained, and jobs placed?
7. What does Equity mean in the context of the Good Jobs Challenge?
8. What other workforce-related terms are important for this NOFO and how do they relate to Department of Labor programs?
9. What do “Work-and-Learn” training models look like?

2. Project Suitability

1. What type of activities are allowable?
2. Can an applicant apply with a project that is comprised only of System Development or Program Design components?
3. What is the maximum request amount for each corresponding period of performance under the Good Jobs Challenge?
4. What do you mean by phased or gated funding?
5. Do I have to complete one phase before I can move on to the next? Can my budget overlap phases?
6. What benchmarks do I need to meet before I can move on to the next phase?
   Please note that specific benchmarks incorporated under a Good Jobs Challenge award may vary.
7. Is a system lead entity allowed to apply for different phases of funding for individual sectoral partnerships?
8. How does EDA define wraparound services? Can these funds be included in our budget?
9. Can the Good Jobs Challenge funding be used for tuition or training costs?
10. What are Employer Commitments?
11. Can youth-serving (e.g., persons under 18) organizations apply for this funding?
12. Can we include pre-apprenticeship programs and costs into our proposal?"
13. Since this is a non-construction grant, can my project train job seekers for the construction industry?

3. Applicant Eligibility

1. Which types of entities are eligible to apply for funding?
2. Does my organization have to be workforce board, regional planning council, or state agency in order to serve as the System Entity Lead for a proposal?
3. What documentation is necessary to prove my non-profit is “acting in cooperation with officials of a political subdivision of a state”?
4. What documentation is required for EDA to waive the requirement that a non-profit organization show that it is “acting in cooperation with officials of a political subdivision of a state”?
5. Will active and/or previous grants that the federal government awarded my organization affect my organization’s eligibility for the Good Jobs Challenge?
6. What project costs are eligible for funding under this competition?
7. Is a quasi-governmental entity, such as a Workforce Board, eligible to apply for this funding?
8. My project will cover an area of significant regional or national scope. Is it a requirement to show cooperation with local government officials for all of the area that my project will cover?
9. In order to apply as a nonprofit organization must I be legally organized as a 501(c)(3)?
10. Are organizations that operate as 501(c)(6) nonprofits eligible for EDA assistance?

4. Lead Applicants, Subawards, Contractors, Co-Applicants

1. Who should be the lead applicant for a Good Jobs Challenge application?
2. What is the difference between a co-applicant, a subrecipient, and a contractor?
3. How do you determine whether an entity is a co-applicant? What forms are co- applicants required to submit?
4. What differentiates a subrecipient from a co-applicant?
5. What differentiates a contractor from a co-applicant?
6. My application includes partners who will be applying as part of my system. Should we apply as co-applicants?

5. Comprehensive Economic Development Strategy (CEDS) Requirements

1. Do the activities proposed under the Good Jobs Challenge have to be aligned with a Comprehensive Economic Development Strategy (CEDS)?
2. How do I locate the applicable CEDS for my region? What if my project covers multiple planning districts or states?
3. May we still apply if our region does not have a CEDS?

6. Application Guidelines

1. What should be in the Project Narrative?
2. How will my application be scored?
3. Is there a Matching Share requirement?
4. Are letters from stakeholders required?
5. Should I include a staffing plan with my application?
6. What reporting or performance metrics will be collected by EDA?
7. My project will cover an area of significant regional or national scope. Is it a requirement to show cooperation with local government officials for all of the area that my project will cover?
8. Can we submit multiple applications for the Good Jobs Challenge?
9. My organization is a national organization that works in multiple regions throughout the US. How should I define region in my project?
10. Do I need to submit Form SF-LLL (Disclosure of Lobbying Activities) with my application?
11. What formatting is required for submission of materials?
12. I’m not seeing Form ED-900A in Grants.gov, is this form still required for submission?
13. What is the expected period of performance for this grant?

7. Financial Compliance, Indirect Costs, and Reporting

1. Should the budget reflect funds allotted by year or for the entire period of performance?
2. Can grant funds be used to provide wages or stipends to program participants?
3. Can I charge indirect costs to this project? How do applicants without a current or pending NICRA account for indirect costs in the Budget Narrative?
4. Are subrecipients able to include indirect costs in their budget, either by NICRA or the Federal de minimis?
5. If my organization is applying for system development and/or program design funding, and the details of program implementation are not yet fully determined, how should we structure our budget?
6. My organization is applying with a project that includes wraparound services for program participants. How should these wraparound services be included in our budget?
7. We are planning on leveraging other federal funds for our program; how should we document that in the budget narrative template?

8. Contact Us

1. What should I do if I have additional questions not answered in this FAQ? How do I get in touch with EDA?

Introduction and Key Definitions

a. What is the Good Jobs Challenge?

The Good Jobs Challenge, one of EDA’s six innovative American Rescue Plan programs, will make $500 million available to help train Americans for good jobs by developing and strengthening regional workforce training systems and sectoral partnerships. These systems and partnerships will create and implement industry-driven training programs, designed to connect unemployed, underemployed, or under-skilled workers to existing and emerging job openings. Ultimately, these systems are designed to train workers with the skills to secure quality jobs, that provide good-pay, benefits, and growth opportunities, such as a union job.

Examples of systems and training delivery models can be found in the NOFO in sections A.1.b.i and A.1.b.iv.

b. What is a “sectoral partnership” and a “regional workforce training system”?

For purposes of the Good Jobs Challenge:

• A “sectoral partnership” is a partnership of employers from the same industry who join with other strategic partners to train and place workers into high-quality jobs that employers need filled and intend to fill through the partnership. The strategic partners can include: government, education (including community and technical colleges), training organizations, economic development organizations, workforce development organizations, unions, labor management partnerships, industry associations, employer-serving organizations, and/or community-based organizations. A sectoral partnership is focused on one specific industry or functional area (e.g., finance, customer service), and one or more specific roles within that industry. Sectoral partnerships are effective because: they are carefully built to include all necessary partners before workforce solutions are designed; they cut across traditional economic development, workforce, education, and social services system silos; they are targeted to in-demand sectors with high-quality jobs; and they consider the economic realities of a regional industry in assessing workforce demand and training needs. Sectoral partnerships heighten the chance of job placement after program completion given their connection to real-time employer demand.
  • The lead entity of a sectoral partnership is referred to in this NOFO as a “Backbone Organization.” See question 1.d. below for additional information on Backbone Organizations.
• A “regional workforce training system” is a system that fosters and supports multiple sectoral partnerships. A mature regional workforce training system will include a lead entity and multiple sectoral partnerships, each with their own Backbone Organization (though one Backbone Organization could lead multiple sectoral partnerships), training provider(s), and industry partners. The lead entity (e.g., a state government, municipal government, state workforce board, local workforce board) coordinates across and supports the sectoral partnerships within its system. A regional workforce training system may also include other entities that support across multiple sectoral partnerships (e.g., a community-based organization that supports recruiting for all of the sectoral partnerships). In a region that does not yet have a regional workforce training system, interested partners are encouraged to join together to apply for funding under this NOFO to develop such a system. Interested parties would include a convener (e.g., a state government, municipal government, state workforce board, local workforce board) who is an eligible EDA applicant as well as entities interested in forming sectoral partnerships (e.g., employers, training providers, unions, community-based organizations).

*Note: A “regional workforce training system” as used in this NOFO is not to be confused with a Workforce Innovation and Opportunity Act (WIOA) system. See question 1.c. below.

Figure 1 offers a visualization of how different entities work together in a sectoral partnership and Figure 2 gives an illustrative example of a regional workforce training system.

Figure 1 – Visualization of a Sectoral Partnership:

Figure 2 – Illustrative Example of a Regional Workforce Training System:

Although not required, EDA encourages efforts to reach historically underserved populations and areas, communities of color, women, and other groups facing labor market barriers such as persons with disabilities, disconnected youth, individuals in recovery, individuals with past criminal records, including justice impacted and reentry participants, serving trainees participating in the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF) and Women, Infants and Children (WIC), and veterans and military spouses. EDA also encourages partnerships with community-based organizations, Historically Black Colleges and Universities, Tribal Colleges and Universities, or Minority-Serving Institutions.

See Section A.1.b. of the NOFO for addition details and examples.

c. Are regional workforce training systems the same as Workforce Innovation and Opportunity Act (WIOA) systems?

No. Regional workforce training systems may include WIOA systems or their component organizations, but regional workforce training systems are not limited to WIOA systems and may not always include a Workforce Development Board as a partner. Other key partners may include employers, educational institutions, training providers, community-based organizations, unions, and employer-serving organizations (e.g., chambers).

d. What is a “System Lead Entity” and a “Backbone Organization”?

Applicants may submit projects for a regional workforce training system made up of several sectors / industries, or they may submit projects for a single sectoral partnership (one sector / industry). A System Lead Entity leads and convenes a multi-sector regional workforce training system, while a Backbone Organization leads and convenes a single-sector sectoral partnership.

A strong System Lead Entity or Backbone Organization for each system or partnership is a key element to the success of the system. An effective System Lead Entity or Backbone Organization will have some or all of the following characteristics:

• Convening power in the region;
• Committed support of the executive leadership from the region and buy-in from appropriate stakeholders depending on the affected region (e.g., a governor, mayor or chief executive of a jurisdiction, chief executives of a major employers, heads of labor unions, presidents of two- and four-year institutions of higher education, etc.);
• Relationships and credibility with key players in the workforce ecosystem, including employers, governmental entities, state or local workforce development boards, educational institutions, labor organizations, community-based organizations, and worker-serving organizations;
• A proven track record of coordinating across sectors and partners and of driving stakeholders to successful action;
• Ability to translate various sectors’ objectives and key concerns to other sectors (System Lead Entity only);
• Strong fundraising capabilities or for Backbone Organizations, connection to a system with strong fundraising capabilities; and
• Dedicated full-time employee(s) focused on regional workforce issues to support regional economic development.

EDA will make awards to either the System Lead Entity of a regional workforce system or the Backbone Organization of a sectoral partnership to fund key activities in workforce development systems. The System Lead Entity or Backbone Organization will be the lead applicant in this challenge and must be an eligible entity (see question 3.a. below). Other stakeholders may be involved depending on the scope of work, including co-applicants, sub-awardees (aka, subrecipients), and contractors.

See Section A.1.b. of the NOFO for addition details and examples.

e. What is a quality job or a good-paying job?

A quality job (or a “good-paying job”) is a job that exceeds the local prevailing wage for an industry in the region, includes basic benefits (e.g., paid leave, health insurance, retirement/savings plan) and/or is unionized, and helps the employee develop the skills and experiences necessary to advance along a career path. “Prevailing wage” is defined by the Department of Labor as “the average wage paid to similarly employed workers in a specific occupation in the area of intended employment.”

f. What is the difference between jobs created, jobs retained, and jobs placed?

• Jobs created are new jobs that are directly or indirectly generated from EDA grant funding or associated follow-on private investment.
• Jobs retained are jobs that existed prior to EDA grant funding that would have disappeared without EDA investment.
• Jobs placed are jobs that had or will have vacancies prior to EDA grant funding and, due to EDA investments, now have workers matched or placed into those jobs.

g. What does Equity mean in the context of the Good Jobs Challenge?

Equity is defined in EDA’s Investment Priorities as projects or programs that that directly benefit:

1. one or more traditionally underserved populations (PDF), including but not limited to women, Black, Latino, and Indigenous and Native American persons, Asian Americans, and Pacific Islanders; or
2. underserved communities within geographies that have been systemically and/or systematically denied a full opportunity to participate in aspects of economic prosperity such as Tribal Lands, Persistent Poverty Counties (XLSX), and rural areas with demonstrated, historical underservice.

For more information on these populations and geographies see: https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/.

Underserved communities could also include historically underserved populations and areas, communities of color, women, and other groups facing labor market barriers such as persons with disabilities, disconnected youth, individuals in recovery, individuals with past criminal records, including justice impacted and reentry participants, serving trainees participating in the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF) and Women, Infants and Children (WIC), and veterans and military spouses.

Helpful resources include:

• The EDA-funded Stats America website (https://www.statsamerica.org/);
• The Internal Revenue Service’s designation of Opportunity Zones by Census tract (https://www.irs.gov/pub/irs-drop/n-18-48.pdf (PDF)); and
• The U.S. Department of Agriculture, Economic Research Service’s measures of various distress indicators for counties (https://www.ers.usda.gov/data-products/county-typology-codes/).

h. What other workforce-related terms are important for this NOFO and how do they relate to Department of Labor programs?

Below are some terms that are frequently used in the Department of Labor and WIOA context:

Career pathway: The term ‘‘career pathway’’ means a combination of rigorous and high-quality education, training, and other services that— (A) aligns with the skill needs of industries in the economy of the State or regional economy involved; (B) prepares an individual to be successful in any of a full range of secondary or postsecondary education options, including apprenticeships registered under the National Apprenticeship Act; (C) includes counseling to support an individual in achieving the individual’s education and career goals; (D) includes, as appropriate, education offered concurrently with and in the same context as workforce preparation activities and training for a specific occupation or occupational cluster; (E) organizes education, training, and other services to meet the particular needs of an individual in a manner that accelerates the educational and career advancement of the individual to the extent practicable; (F) enables an individual to attain a secondary school diploma or its recognized equivalent, and at least 1 recognized postsecondary credential; and (G) helps an individual enter or advance within a specific occupation or occupational cluster.

In-demand industry sector or occupation: The term ‘‘in-demand industry sector or occupation’’ means— (i) an industry sector that has a substantial current or potential impact (including through jobs that lead to economic self-sufficiency and opportunities for advancement) on the State, regional, or local economy, as appropriate, and that contributes to the growth or stability of other supporting businesses, or the growth of other industry sectors; or (ii) an occupation that currently has or is projected to have a number of positions (including positions that lead to economic self-sufficiency and opportunities for advancement) in an industry sector so as to have a significant impact on the State, regional, or local economy, as appropriate. The determination of whether an industry sector or occupation is in-demand under this paragraph is made by the State board or local board (defined below), as appropriate, using State and regional business and labor market projections, including the use of labor market information.

Local board: The term ‘‘local board’’ means a local workforce development board established under WIOA section 107. See definition of “Workforce development board” below.

State board: The term ‘‘State board’’ means a State workforce development board established under WIOA section 101. See definition of “Workforce development board” below.

Workforce development board: Workforce development boards convene State, regional, and local workforce system and partners, to: (a) enhance the capacity and performance of the workforce development system; (b) align and improve the outcomes and effectiveness of Federally-funded and other workforce programs and investments; (c) through these efforts, promote economic growth; (d) engage public workforce system representatives, including businesses, education providers, economic development, labor representatives, and other stakeholders to help the workforce development system achieve the purpose of the WIOA; and (e) assist to achieve the State's strategic and operational vision and goals as outlined in the State’s WIOA plan.

i. What do “Work-and-Learn” training models look like?

EDA does not have a set definition of work-and-learn models under the Good Jobs Challenge. Section A.1.b.iv. (pg. 13) of the Good Jobs NOFO gives examples of the types of training models EDA seeks to fund. Some examples include Registered Apprenticeships, youth apprenticeships, on-the-job training programs, internships, etc.

Please see the Merit Review criteria of the Good Jobs Challenge (section E.1.a, starting on pg. 27) for important information on how EDA will evaluate applications – specifically the criteria on “Employer partnerships.”

2. Project Suitability

a. What type of activities are allowable?

The Good Jobs Challenge is intended to fund non-construction workforce development activities through a single integrated award for either a sectoral partnership or a regional workforce training system. The Good Jobs Challenge is designed to develop or strengthen regional workforce training systems and sectoral partnerships.

See also question 3.d below for more details on allowable costs.

EDA will fund proposals with one or more of the following three phases of the system and/or sectoral partnership lifecycle, as applicable to regional needs:

1. System Development funding to help a System Lead Entity or Backbone Organization establish and develop a regional workforce training system or sectoral partnerships
2. Program Design funding for sectoral partnership(s) to identify the skills needed by industry and workers, develop the skills training curriculum and materials, and secure technical expertise needed to train workers with the skills needed by businesses, including providing professional development and capacity-building to trainers and educators. Employer commitments to hire should also be secured in this phase.
3. Program Implementation funding to deliver workforce training and wrap-around services that will place workers into quality jobs through a new or expanded sectoral partnership(s)

Examples of eligible activities under each phase include:

As an example, a manufacturing trade association brings together multiple employers. They find they all have common job openings for computerized numerical control (CNC) programming and operations and there is inadequate local supply and capacity to meet their demand. With this information, a local training center and community colleges who offer 12-18 week programs in the region partner to form a sectoral partnership to scale existing programs. In addition, the employers offer new work-based learning opportunities for students in the program to begin working at the companies and offered full-time operator positions upon completion of the program. The sectoral partnership also partners with local workforce boards to connect displaced workers with these training programs, and offer to pay for the full cost of training. Further, they partner with community-based organizations to expand opportunities for underserved communities and provide needed wrap-around supports like childcare, transportation, as well as helping participants navigate additional government supports available to them such as SNAP, internet subsidies, etc.

Another example might involve a union working with an employer or group of employers to create or scale a Registered Apprenticeship or an employer-led partnership that provides a work-and-learn model where workers can continue to work as they develop new skills.

EDA recognizes that various regions or various industries within a region have different needs with respect to regional workforce training systems and sectoral partnerships. For example, one region may need to build and design a new sectoral partnership, while another region may have the various components of an effective partnership but may need to link those components in an integrated fashion. A third region may have an existing sectoral partnership that functions well and is ready to move forward with implementation projects or to expand the partnership to other regions or to support other industries and occupations or skill needs within an industry. All of these examples, and more, are eligible for funding under this NOFO.

b. Can an applicant apply with a project that is comprised only of System Development or Program Design components?

Yes, a project may be comprised of System Development or Program Design components so long as there is a Program Implementation phase that is included, whether funded by EDA or not. EDA is open to proposals that:

• Have already completed System Development and/or Program Design phases and only need funding for Program Design and/or Program Implementation.
• Have secured outside funding for certain phases but need EDA funding for the remaining phases.

All projects must include Program Implementation, but the source of funding for Program Implementation does not need to be from EDA.

Applicants will need to demonstrate successful completion of a previous phase by submitting documentation to show the activities listed above in each phase have been completed.

c. What is the maximum request amount for each corresponding period of performance under the Good Jobs Challenge?

Under the Good Jobs Challenge NOFO, EDA is allocating $500 million. EDA anticipates making approximately 25 - 50 awards under the Good Jobs Challenge and expects projects to range in duration from 24 - 36 months. See section 2.A.5 in the NOFO for further detail.

For each project (note: a project could include development of a regional workforce training system and multiple sectoral partnerships):

• Approximately $1 million may be requested for System Development to establish a regional workforce training system and/or sectoral partnership(s).
• Approximately $2 million may be requested for Program Design to design an employer-driven skills training program and secure the needed capital (e.g., equipment, leased space) per region, industry, and worker role.
• Between approximately $2 million and $7 million may be requested for Program Implementation to implement an employer-driven skills training program per region, industry, and worker role.

These examples could be proportionally higher if addressing multiple sectors. E.g., if addressing two sectors: $2 million for System Development, $4 million for Program Design, and $4-14 million for Program Implementation.

The figures provided here are illustrative. Applicants must justify the amount requested in their program design and Budget Narrative.

d. What do you mean by phased or gated funding?

To access each successive phase of funding along the workforce system lifecycle, from System Development to Program Design to Program Implementation, a grantee must demonstrate successful completion of the following activities in each phase:

An applicant must demonstrate successful completion of a phase -- regardless of whether the phase is funded by EDA -- before it can access EDA funds for the next phase. For example, if a project is requesting Program Design and Program Implementation funds, it must first demonstrate successful completion of the System Development phase.

e. Do I have to complete one phase before I can move on to the next? Can my budget overlap phases?

Before moving to each successive phase, you should substantially complete the benchmarks for that phase. However, we understand that the timeline of activities may need to overlap a bit in order to complete your Scope of Work within the period of performance. Any overlap should be clearly defined in your Scope of Work and budget.

f. What benchmarks do I need to meet before I can move on to the next phase?

Below are example benchmarks that we expect most recipients will need to demonstrate before moving on to the next phase:

Please note that specific benchmarks incorporated under a Good Jobs Challenge award may vary.

g. Is a system lead entity allowed to apply for different phases of funding for individual sectoral partnerships?

Yes. In an application with multiple sectoral partnerships, you can have different sectoral partnerships engaging at different phases depending on the needs of the sectoral partnerships.

h. How does EDA define wraparound services? Can these funds be included in our budget?

Wraparound services or “participant support costs” are important services that mitigate barriers to employment for trainees, students, and workers to help them complete workforce training activities. Examples include costs that are necessary for participation in the program, such as transportation, language support, financial coaching, childcare, career navigation and coaching, and access to technology. The definition of “participant support costs” can be found at 2 C.F.R. § 200.1 . Please note costs such as work stipends or wage subsidies are not allowable under the Good Jobs Challenge.

EDA is not authorized to provide grants directly to individuals under this program. Please note, funding for these types of activities should be facilitated through a competitively contracted service provider (intermediary).

i. Can the Good Jobs Challenge funding be used for tuition or training costs?

Yes, tuition costs are generally considered an eligible training cost under this NOFO. Both tuition and training costs are eligible components of an overall operating budget for EDA funding in the Good Jobs Challenge (including instructor salary and benefits).

However, no funds may be paid directly to individuals; award funds should be used to offset the costs of tuition and training and managed by the grantee. Tuition or training costs unrelated to the training program funded under the EDA grant are not eligible.

j. What are Employer Commitments?

EDA is seeking applications that have firm employer commitments to hire. The employer commitment may come in different formats. Examples include:

• Work-and-Learn, including Registered Apprenticeships: See descriptions above.
• Conditional Hiring: An employer hires a worker on the condition of successful completion of the training program and demonstration of skill acquisition.
• Employer Commitments to Hire: Employers commit to hiring a specific number of workers who successfully complete the training program provided through the regional workforce training partnership.

Employer commitments can be documented by a written communication (including an email) from an authorized representative of the employer confirming the type of commitment that is attached to the application. Employer commitments to hire are NOT required, but given the focus of this program on creating quality jobs, will help make your application more competitive. Please see the Merit Review criteria of the Good Jobs Challenge (section E.1.a, starting on pg. 27) for important information on how EDA will evaluate applications – specifically the criteria on “Employer partnerships.”

Given their history of success for workers and employers, EDA encourages applicants and employers to utilize the Registered Apprenticeship program framework or build on existing Registered Apprenticeships, which combine paid on-the-job training under the direction of a mentor with classroom instruction and result in an industry-recognized credential certifying occupational proficiency.

k. Can youth-serving (e.g., persons under 18) organizations apply for this funding?

Yes. Youth-serving organizations that are EDA-eligible entities are eligible to apply for this funding. Note that immediate job placement is a primary goal of this program, successful applicants will need to demonstrate that they are creating a pipeline of skilled job seekers for quality jobs. Traditional K-12 education programs that are not a part of a broader workforce framework may not be as competitive.

l. Can we include pre-apprenticeship programs and costs into our proposal?

The intent of the Good Jobs Challenge is to help fill immediate workforce needs. While pre-apprenticeship programs help build pipelines, the intent of the program is to place participants in jobs within two years of the start of the grant. In general, the costs of pre-apprenticeship programs may be allowable, but we would encourage applicants to review the Merit Review criteria set out in the NOFO and consider how these programs can best meet the outcomes expected of the Good Jobs Challenge.

m. Since this is a non-construction grant, can my project train job seekers for the construction industry?

Yes. A “non-construction grant” is a classification of the type of grant and is not an indication of the industries it serves. For instance, a “construction grant” from EDA would fund new construction projects, while a “non-construction grant” would fund programmatic components. Workforce training for the construction industry IS allowable under the Good Jobs Challenge. Applicants can include programmatic components (e.g., system development, program design, program implementation) that will support the workforce of the construction industry. Please note, however, that while training for the construction industry is allowed, EDA funds cannot be used to build new or remodel existing structures. Rather, projects could include workforce training for construction roles, such as plumbing, cabinetry, general tool operation, etc.

3. Applicant Eligibility

a. Which types of entities are eligible to apply for funding?

Eligible applicants for grants under this NOFO include a(n):

1. District Organization of an EDA-designated Economic Development District (EDD);
2. Indian Tribe or a consortium of Indian Tribes;
3. State, county, city, or other political subdivision of a State, including a special purpose unit of a State or local government engaged in economic or infrastructure development activities, or a consortium of political subdivisions;
4. Institution of higher education or a consortium of institutions of higher education (this could include community colleges, Historically Black Colleges and Universities, Tribal Colleges and Universities, or Minority-Serving Institutions)
5. Public or private non-profit organization or association, including labor unions, acting in cooperation with officials of a political subdivision of a State.¹

EDA is not authorized to provide direct financial assistance to individuals, small businesses, or for-profit entities, including for-profit institutions of higher education, under the Good Jobs Challenge. Applications from such entities will not be considered for funding.

Any of the entities listed above can serve as a System Lead Entity and/or Backbone Organization.

b. Does my organization have to be workforce board, regional planning council, or state agency in order to serve as the System Entity Lead for a proposal?

No. To be a System Entity Lead or a Backbone Organization under the Good Jobs Challenge your organization can be any of the eligible entities named in Section C.1 of the NOFO (and in section 3.a of this FAQ document).

c. What documentation is necessary to prove my non-profit is “acting in cooperation with officials of a political subdivision of a state”?

To be eligible under this NOFO as a public or private non-profit entity, organizations should include at least one letter of support from a political subdivision of a state (e.g., a county or a municipality) that is served by the project. This requirement applies to the proposed System Lead Entity or Backbone Organization that will receive and administer the award if selected.

EDA, at its sole discretion, may waive this cooperation requirement for certain projects of a significant regional or national scope. 13 CFR § 301.2.

d. What documentation is required for EDA to waive the requirement that a non-profit organization show that it is “acting in cooperation with officials of a political subdivision of a state”?

As noted above in FAQ 3.c, for a non-profit to be eligible under the Good Jobs Challenge, the non-profit must demonstrate that it is acting in cooperation with a political subdivision of a state (e.g., a county or a municipality). However, in accordance with the regulation at 13 CFR § 301.2, EDA may waive this requirement for certain projects of significant regional or national scope on a case-by-case basis based on the facts and circumstances surrounding a particular project. If your project is of significant regional or national scope (in general, if the project serves more than a small number of jurisdictions – cities, counties, parishes, etc.) and it is impracticable to obtain the support of the political subdivisions or a majority of the political subdivisions in the project region, you should include that justification in your application.

Please see the Merit Review criteria of the Good Jobs Challenge (section E.1.a, starting on pg. 27) for important information on how EDA will evaluate applications – specifically the criteria on “System Lead Entity’s or Backbone Organization’s capacity” and “Regional investment and sustainability.”

e. Will active and/or previous grants that the federal government awarded my organization affect my organization’s eligibility for the Good Jobs Challenge?

Unsatisfactory performance under prior federal awards may result in an application not being considered for funding.

Applicants that are current recipients of EDA awards and/or CARES Act funding are generally eligible to apply for funding under the Good Jobs Challenge. Proposed project activities and outcomes from prior EDA awards and CARES Act federal funding cannot be co-mingled with Good Job Challenge activities and/or funds. All grant awards and projects must remain distinct and separate from the project submitted for the Good Jobs Challenge.

f. What project costs are eligible for funding under this competition?

Funding under the Good Jobs Challenge should support programmatic costs. All awards will be subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (OMB Uniform Guidance) at 2 C.F.R. part 200 .

Neither the Department of Commerce (DOC) nor EDA will be held responsible for application preparation costs.

Equipment costs, expenses related to securing adequate space (e.g., rent, leases), and other non-construction capital expenses are allowable expenses under this program. Building-based construction projects (i.e., any activity that disturbs the ground or modifies a structure) are not eligible under this NOFO. (For funding to support a building-based construction project to support their workforce development ecosystem, EDA encourages eligible entities to apply under the American Rescue Plan Economic Adjustment Assistance (EAA) NOFO (that was published separately).²

See also questions 2.e. and 2.f. for examples of other allowable expenses.

The use of project funds to make equity or hybrid investments in businesses is not an allowable cost; neither EDA funds nor matching share may be used for such purposes.

Please note that, in general, EDA will not reimburse pre-award project costs, and under no circumstances will EDA or DOC be held responsible for application preparation expenditures, which are distinguished from pre-award project costs.

g. Is a quasi-governmental entity, such as a Workforce Board, eligible to apply for this funding?

It depends. Organizations that are considered a “political subdivision of a State”, including a special purpose unit of a State or local government engaged in economic or infrastructure development activities, are eligible. If your organization is a non-profit in good standing with the state where it is organized, your organization is likely eligible as a non-profit organization.

Reach out to [email protected] with applicable organizational documentation (and incorporation documents, if applicable) to confirm your organization’s eligibility status.

h. My project will cover an area of significant regional or national scope. Is it a requirement to show cooperation with local government officials for all of the area that my project will cover?

EDA’s authorizing legislation requires that non-profit applicants show that they are acting in cooperation with a political subdivision of a state. To meet this requirement, a non-profit applicant will be required demonstrate that support via a letter from at least one political subdivision of a state (i.e. a county or a municipality). For projects covering large geographic areas, EDA recommends applicants get support letters that cover the majority of the region.

EDA may waive this cooperation requirement for certain projects of a significant regional or national scope at the agency’s discretion (under EDA’s regulation at 13 CFR 301.2(b)).

If your project is of significant regional or national scope (in general, if the project serves more than a small number of jurisdictions – cities, counties, parishes, etc.) and it is impracticable to obtain the support of the political subdivisions or a majority of the political subdivisions in the project region, you should include that justification in your application.

i. In order to apply as a nonprofit organization must I be legally organized as a 501(c)(3)?

For eligibility purposes, nonprofit organizations are not required to have any form of status with the IRS, including 501(c)(3) status. An eligible nonprofit organization must be an entity organized in accordance with applicable state law that is, in accordance with the definition of nonprofit organization at 2 CFR 200.1, “(1) operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (2) not organized primarily for profit; and (3) uses its net proceeds to maintain, improve, or expand the operations of the organization.” The applicant will be required to provide relevant organizational documentation, including a current certificate of good standing, articles of incorporation, and bylaws.

In addition, although Merit Review criteria are set out in the Good Jobs Challenge NOFO, as a general matter, EDA will assess the applicant’s capacity and ability to successfully execute the proposed project.

j. Are organizations that operate as 501(c)(6) nonprofits eligible for EDA assistance?

As noted above, an eligible nonprofit organization must be an entity organized in accordance with applicable state law that is, in accordance with the definition of nonprofit organization at 2 CFR 200.1, “(1) operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (2) not organized primarily for profit; and (3) uses its net proceeds to maintain, improve, or expand the operations of the organization.”

As a general matter, a 501(c)(6) nonprofit may be eligible for EDA assistance so long as the organization:

• Is properly organized as a nonprofit in accordance with state law and the definition of 2 CFR 200.1.
• Is authorized to undertake activities eligible under the Good Jobs Challenge NOFO. For the Good Jobs Challenge, the applicant must be authorized to undertake eligible workforce-related activities.
• Does not use EDA funds for unauthorized purposes, such as lobbying. If an organization is authorized to undertake unauthorized activities, such as lobbying, EDA may require the applicant to certify that the applicant will not use EDA grant funds for such purposes.

In addition, as noted above in FAQ # 3.j above, although specific Merit Review criteria are set out in the relevant NOFO, as a general matter, EDA will assess the applicant’s capacity and ability to successfully execute the proposed project.

4. Lead Applicants, Subawards, Contractors, Co-Applicants

a. Who should be the lead applicant for a Good Jobs Challenge application?

An eligible entity that is the System Lead Entity or Backbone Organization will be the lead applicant in this challenge. Other stakeholders may be involved depending on the scope of work, including co-applicants, subrecipients, and contractors. See questions 1.d. and 3.a. above for details and definitions of System Lead Entity and Backbone Organization.

EDA encourages partnerships with Historically Black Colleges and Universities, Tribal Colleges and Universities, or Minority-Serving Institutions.

b. What is the difference between a co-applicant, a subrecipient, and a contractor?

The following table provides general information about each type of entity.

c. How do you determine whether an entity is a co-applicant? What forms are co- applicants required to submit?

If another entity will be partnered with the lead applicant in managing and implementing the scope of work of an award, then that entity may be considered a co-applicant. Co-applicants are generally required to submit the same forms that the Lead Applicant must submit. These additional forms (SF-424, organizational documents, lobbying forms, NICRA) should be attached to the same application as the Lead Applicant.

d. What differentiates a subrecipient from a co-applicant?

Co-applicants jointly manage and implement the scope of work of an award. In contrast, subrecipients carry out a portion of project activities on behalf of the Lead Applicant or co- applicant(s). Any subrecipient must be an eligible entity under this NOFO. Many funded stakeholders may likely qualify as a subrecipient. For more information on determining whether a third-party is a subrecipient, see 2 CFR § 200.331 (Subrecipient and contractor determinations).

e. What differentiates a contractor from a co-applicant?

Co-applicants jointly manage and implement the scope of work of an award. In contrast, contractors provide goods and services for the applicant’s or co-applicants’ use in performing the scope of work of an award. Most contractors would not meet eligibility status under this NOFO (i.e., mostly for-profit entities). For more information on determining whether a third-party is a contractor, see 2 CFR § 200.331 (Subrecipient and contractor determinations). Contracts must be procured in accordance with the procurement standards at 2 CFR §§ 200.317-327 of the OMB Uniform Guidance.

f. My application includes partners who will be applying as part of my system. Should we apply as co-applicants?

EDA is requesting for applicants to designate one lead applicant, the System Lead Entity, who will submit a complete application. Other partners, including backbone organizations, will serve as subrecipients or contractors. These partners will not need to complete any of the required application forms, and the project budget should be inclusive of their costs. EDA recommends utilizing the optional budget template on our website for more information of how to include subrecipient costs in your budget.

5. Comprehensive Economic Development Strategy (CEDS) Requirements

a. Do the activities proposed under the Good Jobs Challenge have to be aligned with a Comprehensive Economic Development Strategy (CEDS)?

Yes, each project funded under this NOFO must demonstrate consistency with the region’s current Comprehensive Economic Development Strategy (CEDS) or an equivalent EDA-accepted regional economic development strategy that meets EDA’s CEDS or strategy requirements.

Find your CEDS here: https://www.statsamerica.org/ceds/

CEDS are locally-based and regionally driven economic development planning processes, , typically prepared by an EDA-designated Economic Development District (EDD) organization, to guide capacity building efforts that best serve economic development in the region. Documents for consideration as a CEDS equivalent can include various regional economic development plans (or a combination of plans), including but not limited to regional comprehensive plans, regional resilience plans, or recovery plans.

Each application for the Good Jobs Challenge should include in their Project Narrative a discussion of how the collection of proposed component projects, as a whole, will support the economic development needs and objectives outlined in the appliable CEDS or equivalent strategy(ies). Applicants may also include letters of support from organizations that prepare CEDS or equivalent plans for areas that will be served by the proposed system and/or project.

b. How do I locate the applicable CEDS for my region? What if my project covers multiple planning districts or states?

EDA supports the CEDS Resource Library where applicants can determine whether their region is served by an Economic Development District (EDD) organization and locate its most recent CEDS. Because of the regional footprint of the projects anticipated by this NOFO, applicants may need to show alignment with multiple CEDS or regional or statewide equivalents.

Applicants may contact the EDA Representative for their area listed at eda.gov/contacts/ (and in NOFO Section G) for assistance to locate the applicable CEDS or equivalent plan(s).

c. May we still apply if our region does not have a CEDS?

Applicants from geographies that are not covered by an EDD are encouraged to reach out to the EDA at [email protected] to help determine a CEDS-equivalent.

6. Application Guidelines

a. What should be in the Project Narrative?

The project narrative should describe in depth the proposed work to be done under this grant opportunity. Please see section D.2.a of the NOFO for full details.

b. How will my application be scored?

All complete applications will be reviewed by at least three individuals and scored against the Merit Review criteria provided in section E.1.a of the NOFO. EDA anticipates funding awards to the highest scoring projects after application of selection factors described in section E.1.b of the Good Jobs Challenge NOFO.

c. Is there a Matching Share requirement?

Matching share is not a requirement for this funding opportunity; however, applicants may choose to provide match as part of the project. This may be taken into consideration for scoring purposes regarding the capacity of a System Lead Entity or Backbone Organization.

EDA generally expects to fund 100% of eligible project costs, given the extent of the economic impact and in accordance with the agency’s statutory authority under section 703 of PWEDA (42 U.S.C. § 3233). For more information on how this type of funding would affect the application’s competitiveness, please see section E.1 of the NOFO.

d. Are letters from stakeholders required?

Yes, System Lead Entities or Backbone Organizations should submit letters of commitment from all system stakeholders involved in the project. Letters should be signed by an authorized representative from the stakeholder organization, articulate what role the organization will fill within the context of the project, and general support for the project. Additional letters of support from non-stakeholder organizations can be included as well (optional). There is no cap on number of letters that can be included in the application. Letters of support do not count towards the project narrative page limit.

e. Should I include a staffing plan with my application?

Yes, you should include a staffing plan, an outline and key biographies for key team members on your project narrative. If they are funded staff under this grant, make sure to also include in your budget. This information will help EDA determine the System Lead Entity and/or Backbone Organization’s capacity to carry out the project and will impact this scoring criterion. Click here to review a Staffing Plan template. (XLSX)

f. What reporting or performance metrics will be collected by EDA?

All awardees should produce concrete, measurable impacts for workers in the region (e.g., employer commitments to hire, job placements, wage gain). These metrics should also be broken down by demographics in order to track progress against equity goals.

Metrics that will need to be tracked and reported may include the following: number of workers participating in program broken down by key demographics, number of workers who complete the program broken down by key demographics, number of workers placed into jobs broken down by key demographics, average wages of job placements, average wage growth of job placements, retention of workers placed, amount spent on wraparound services, and total average cost spent per worker.

All EDA grants are subject to semi-annual and annual reporting requirements. In addition, this program may implement additional reporting requirements such as tracking participant data. We would encourage applicants to consider their data management plan for this program. Database costs used directly for this program’s requirements may be considered an allowable expense under this NOFO.

EDA is developing additional performance metrics that grantees will have to submit through GPRA (pursuant to section F.5.c of the NOFO). Further details will be shared after award.

g. My project will cover an area of significant regional or national scope. Is it a requirement to show cooperation with local government officials for all of the area that my project will cover?

The requirement that projects of non-profit organizations show that they are acting in cooperation with a political subdivision of a state is a statutory requirement under EDA’s authorizing legislation. However, EDA may waive this cooperation requirement for certain projects of a significant regional or national scope at the agency’s discretion (under EDA’s regulation at 13 CFR 301.2(b)).

The support of appropriate governmental units can help show that the project meets regional needs and may help avoid the risk that the project will not meet EDA’s eligibility criteria. For applications covering large geographic areas, EDA recommends applicant get support letters that cover the majority of the region, or get support letters from appropriate states.

h. Can we submit multiple applications for the Good Jobs Challenge?

An applicant can submit multiple applications as long as the applications are for separate and distinct projects. Be sure to check out the Application Checklist on EDA’s Good Jobs Challenge website (https://eda.gov/arpa/good-jobs-challenge/) for the full list of required forms and supporting documentation to be submitted in Grants.gov.

i. My organization is a national organization that works in multiple regions throughout the US. How should I define region in my project?

The Good Jobs Challenge allows applicants to plan and build within a footprint that makes sense for the applicant’s strategy and for the region or regions the applicant serves. It is up to each applicant to define the region or regions served.

It is important to make sure your project is consistent with the Comprehensive Economic Development Strategy (CEDS) that cover each region that your project will serve. This means you would include multiple CEDS that cover the scope of the regions covered in your application. CEDS can be found at https://www.statsamerica.org/ceds/Default.aspx

Regional model example:

Example of a national model with Sectoral partnerships spanning one region each:

Example of a national model with each sectoral partnership spanning multiple regions:

j. Do I need to submit Form SF-LLL (Disclosure of Lobbying Activities) with my application?

While the NOFO specifies that Form SF-LLL is only is only required if the applicant has retained a registered lobbyist in conjunction with the proposed project, the Grants.gov application portal requires submission of the form for a complete application. Therefore, please complete and submit Form SF-LLL. If the applicant has no relevant lobbying activities to report, the applicant can denote this by inputting “None” or “N/A” in sections 10.a and b. of the form.

k. What formatting is required for submission of materials?

All materials should be submitted via Grants.gov. There is no limit on the number of attachments (outside of what the digital platform will allow).

A Project Narrative of no more than 15 total pages (12-point font, 1-inch margins). Material beyond the 15th page will not be read or considered. There is no preference on whether this is double-spaced or single-spaced. Cover pages/tables of contents are included in this 15-page limit.

Letters of support can be addressed generally to:

Good Jobs Challenge Review Team
U.S. Economic Development Administration
1401 Constitution Ave. NW
Washington, DC 20230

l. I’m not seeing Form ED-900A in Grants.gov, is this form still required for submission?

No. At time of award, if it is determined that this is still needed, your assigned EDA Program Officer will work with you to get this filled out.

m. What is the expected period of performance for this grant?

EDA recommends your budget cover a 24-36 month period of performance. This is the period in which all federal funds are expected to be spent. This applies to the comprehensive scope of work for all phases included.

7. Financial Compliance, Indirect Costs, and Reporting

a. Should the budget reflect funds allotted by year or for the entire period of performance?

Budgets should reflect the entire period of performance for this grant opportunity (24-36 months). Your funding request and associated documents should cover the entire period of performance for your grant. An Optional Budget Narrative and Staffing Plan Template may be found on the Good Jobs Challenge website: https://eda.gov/arpa/good-jobs-challenge/

b. Can grant funds be used to provide wages or stipends to program participants?

No, grant funds cannot be used to provide wages or stipends to participants of the program. Applicants are encouraged to utilize other funding sources should they choose to include participant wages as a component of their program.

c. Can I charge indirect costs to this project? How do applicants without a current or pending NICRA account for indirect costs in the Budget Narrative?

If indirect costs are included in the project budget, the applicant must include documentation to support the indirect cost rate it is using by submitting a copy of its current, approved negotiated indirect cost rate agreement (NICRA). See NOFO section 2.D for full details.

If the applicant does not have a current or pending NICRA, the applicant can elect to apply the 10 percent de minimis rate to modified total direct costs (MTDC). The definition of MTDC can be found at 2 CFR 200.1. If electing to use the de minimis rate, the applicant should include a statement in the budget narrative stating that is does not have a current (or provisional) negotiated indirect rate and is electing to charge the de minimis (see 2 CFR § 200.414(f)).

If the applicant would like to apply for a NICRA, please see section D.2.d in the NOFO for full instructions.

d. Are subrecipients able to include indirect costs in their budget, either by NICRA or the Federal de minimis?

Yes, subrecipients are able to include indirect costs, based on either their NICRA or the Federal de minimis rate. These costs should be included in the subaward budget, which will be listed in the contractual category. It is the responsibility of the System Lead Entity, or lead applicant, to maintain indirect cost documentation for subrecipients.

e. If my organization is applying for system development and/or program design funding, and the details of program implementation are not yet fully determined, how should we structure our budget?

EDA recommends organizing your budget by year to cover the 24-36 month period of performance. Organizations who are applying for the earlier phases of funding should still have some sort of plan for program implementation and how funding will be utilized. This plan can include estimates, but should include an explanation for how these estimates were developed. Keep in mind that, if awarded, the budget submitted will be the budget for the duration of the grant, so these estimates should be as close as possible. EDA will offer some flexibility post-award to allow for costs that cannot be realistically estimated. We recommend utilizing the budget template on our website to help you structure your budget.

f. My organization is applying with a project that includes wraparound services for program participants. How should these wraparound services be included in our budget?

Generally, wraparound services will be provided by a service provider. These services should be included in the contractual category on your budget, since you will be brokering a contract with the provider, who will be providing a service. If awarded, federal procurement standards should be followed, unless the service provider is also an eligible entity under the Good Jobs Challenge NOFO.

g. We are planning on leveraging other federal funds for our program; how should we document that in the budget narrative template?

For each category there is a column that says “federal share” and “non-federal share”. “Federal Share” refers to the EDA grant amount your consortia is requesting, while the “Non-Federal Share” column represents match/leveraged funding for the purposes of this grant. Please put all match/leveraged funding (federal, private, cash, in-kind) in the “non-federal share” column. In addition, all match/leveraged funding should have a signed letter of support highlighting the commitment, whether cash or in-kind is committed for the purposes of the proposed project.

8. Contact Us

a. What should I do if I have additional questions not answered in this FAQ? How do I get in touch with EDA?

Send email inquiries about the American Rescue Plan Good Jobs Challenge to [email protected].

^1. See section 3 of PWEDA (42 U.S.C. § 3122) and 13 C.F.R. § 300.3.

^2. Workforce construction projects may also be funded under the Build Back Regional Challenge, Indigenous Communities, and Travel, Tourism, and Outdoor Recreation NOFOs.