CDE Announcements Archive

Workforce Innovation and Opportunity Act (WIOA), Title II: Adult Education and Family Literacy Act (AEFLA) 2024–25

Dear Adult Education Administrators:

The Office of Management and Budget revised several parts of the Title 2 Code of Federal Regulations (CFR) on April 22, 2024, including 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, also known as the Uniform Grants Guidance or UGG.

The effective date of the 2024 revised UGG provisions in 2 CFR Part 200 for State-Administered programs, including the WIOA, Title II: AEFLA, will be July 1, 2025.

A full copy of the revised 2024 UGG is available at 2 CFR Part 200.

California WIOA, Title II: AEFLA grantees are advised to review the changes carefully and to take steps to update and apply the revisions to internal guidance, policies, and procedures. This notification is intended to bring attention to these important changes as you begin the implementation process but is not comprehensive. We recognize that these revisions may generate questions and encourage agencies to reach out to their Adult Education Office (AEO) regional consultant with any program or organization specific questions.

Here is a summary of some of the more significant changes affecting AEFLA providers that will go into effect on July 1, 2025:

• Clarifying Definitions 2 CFR 200.1. Definition changes including but not limited to: Acquisition cost; Computing devices; Cost objective; Cost sharing; Disallowed costs; Equipment; Financial obligations; Information technology systems; Internal control; recipient; subrecipient; and Supply.
• Equipment 2 CFR 200.1. The per-unit acquisition cost threshold increases from $5,000 to $10,000.

  Note: Although costs for capitalized equipment are not reimbursable with AEFLA funds (State-imposed requirement), grantees must revise their policies and procedures to increase their capitalization threshold for equipment to $10,000 (from $5,000) to exercise the flexibility to apply the new threshold for supplies. See Supply below.
• Supply (including a computer device) 2 CFR 200.1. Note: By updating their capitalization threshold level for equipment to $10,000, AEFLA grantees will not need to make further changes to their thresholds for supplies because the definition of supplies in 2 CFR 200.1 cross-references the definition of equipment. Therefore, equipment, including a computer device, is a supply if the per-unit acquisition cost is below the lesser of the provider’s capitalization threshold level for financial statement purposes or $10,000, regardless of the length of its useful life.
• Mandatory Disclosures 2 CFR 200.113.

  An applicant, recipient, or subrecipient of a Federal award must promptly disclose whenever, in connection with the Federal award (including any activities or subawards thereunder), it has credible evidence of the commission of a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the United States Code or a violation of the civil False Claims Act (31 U.S.C. 3729–3733)…
• Whistleblower Protections 2 CFR 200.217. New: The recipient and subrecipient must inform their employees in writing of employee whistleblower rights and protections under 41 U.S.C. 4712.
• Internal Controls 2 CFR 200.303. Updates include adding the word “document” in subsection(a) and new Cybersecurity Standards: “Take reasonable cybersecurity and other measures to safeguard information including personally identifiable information (PII) and other types of information”.
• Subrecipient and contractor determinations 2 CFR 200.331. New: “The Federal agency does not have a direct legal relationship with subrecipients or contractors of any tier; however, the Federal agency is responsible for monitoring the pass-through entity's oversight of first-tier subrecipients.”
• Requirements for pass-through entities 2 CFR 200.332. New (a): Verifying in SAM.gov that a potential subrecipient is not suspended, debarred or excluded from receiving Federal funds; and (b)(3) additional requirements and certifications.
• Required Certifications 2 CFR 200.415. New (b): Subrecipients under the Federal award must certify to the pass-through entity whenever applying for funds, requesting payment, and submitting financial reports. This applies to all tiers of subrecipients.

  I certify to the best of my knowledge and belief that the information provided herein is true, complete, and accurate. I am aware that the provision of false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative consequences including, but not limited to violations of U.S. Code Title 18, sections 2, 1001, 1343 and Title 31, sections 3729-3730 and 3801-3812 .
• Consideration for selected items of costs 2 CFR 200.420. New:

  (b) The following sections are not intended to be a comprehensive list of potential items of cost encountered under Federal awards. Failure to mention a particular item of cost, including as an example in certain sections, is not intended to imply that it is either allowable or unallowable. When determining the allowability for an item of cost, each case should be based on the treatment provided for similar or related items of cost and based on the principles described in sections 200.402 through 200.411. In case of a discrepancy between the provisions of a specific Federal award and the provisions below, the Federal award governs. Criteria outlined in Section 200.403 must be applied in determining allowability.
• Compensation – personal services 2 CFR 200.430. Standards for Documentation of Personnel Expenses (also known as Time and Effort). No changes but a rearrangement of the references within 2 CFR 200.430(i) to (g).
• Conferences 2 CFR 200.432. If an AEFLA provider is hosting a conference, “The costs of identifying and providing locally available dependent-care resources for participants are allowable as needed.”
• Audit Requirements – Single Audit 2 CFR 200.501 (b). The threshold for single audits increases from $750,000 to $1 Million.

If you have any questions, please contact your AEO Regional Consultant directly or the AEO at 916-322-2175, or by email at adulteducation@cde.ca.gov.

Sincerely,

Carolyn Zachry, Ed.D.
Education Administrator and State Director
Adult Education Office
California Department of Education
916-322-2175
adulteducation@cde.ca.gov