Workforce Investment Act Title I-B
Washington State Policies

BACKGROUND

This policy describes requirements for the acquisition, management and inventory of property, other than real property as defined in Washington State OFM Policy. PL 105-220 Sec.184(a)(2)(A) requires each state, local workforce development area and service provider receiving funds under the Workforce Investment Act (WIA) of 1998, to comply with applicable uniform cost principles including appropriate circulars of the Office of Management and Budget (OMB).

This policy applies to capital assets, but not to real property, i.e. land and buildings. Furniture, fixtures, software, or other "equipment" not an integral part of a building, and with a unit acquisition cost of $5,000 or less, is not considered property, and is to be classified as equipment.

Uniform Administrative Requirements for Grants and Agreements to State and Local Government is codified at 29 CFR Part 97. Institutions of higher education, hospitals, and other non-profit, and commercial organizations must follow the common rule OMB Circular A-110 codified at 29 CFR Part 95, except as provided under 20 CFR 667.200 (a)(3)-(7). Individuals and organizations must adhere to the property management standards as set forth in these sections.

Each Local Workforce Development Area (LWDA) is responsible to have a written policy addressing how they will ensure the management and inventory of all properties obtained using WIA funds, including property purchased with Job Training Partnership Act (JTPA) funds and transferred to WIA.

Each WDA will develop a written policy that complies with WIA, Washington State Office of Financial Management (OFM) policy or, in the cases of local government, the Local Government Property Acquisition Policy. Local policy will, at a minimum, address the following:

1. Grantees will retain property records that provide:

• an item description;
• the serial and model number or other identification number;
• the source of property, including grant or agreement number;
• whether title rests with grantee, state or federal government, other entity;
• acquisition date and cost;
• percent of federal participation in the project that purchased the equipment;
• location, use, condition, and date the information was reported; and
• the date of disposal.

• keep property in good condition;
• use procedures to gain highest possible return on sold items;
• retain all records for three years after disposal of property; and
• tag all property purchased with WIA funds that has a purchase or depreciated 
  value of $5,000

3.  In addition to the above points 1 and 2, for small and attractive assets each grantee:

• should perform a risk assessment (both financial and operational) of the grantee’s
  assets to identify those assets that are particularly at risk or vulnerable to loss. Assets so identified that fall below capitalization policies are considered small and attractive assets.

Areas may use either the following OFM Guidelines State Accounting Manual Section 30.20.70.c or policies established by their local government.

1.  To calculate depreciation using the straight-line method:

Annual Depreciation = Cost – Salvage Value
                                            Asset Useful Life

Capitalized Fixed Assets: Includes all land and all remaining fixed assets with a unit cost of $5,000 or greater.

Equipment: Tangible, non-expendable personal property having a useful life of more than one year and an acquisition cost of more than $5,000.

Fixed Assets: Assets (normally tangible, but including several intangibles) acquired through donation, gift, purchase, capital lease, or self-construction with a life expectancy of more than one year.

Inventoriable Fixed Assets: Includes all capitalized fixed assets plus all fixed assets meeting the definition of small and attractive.

Supplies: All personal property other than equipment.

All fiscal policies and guidance letters published for WIA are governed, as appropriate, under:

• PL 105-220 Sec.184(a)(2)(A)
• 20 CFR Part 652
• 29 CFR Part 95
• 29 CFR Part 97
• OMB Circular A-21: Cost Principles for Education Institutions
• OMB Circular A-87: Revised Cost Principles for State and Local Government and
  Indian Tribal Government
• OMB Circular A-110, __.30 Property Standards
• OMB Circular A-122: Cost Principles for Non-Profits
• OMB Circular A-133: Audit of State and Local Government
• OMB Circular A-133: Compliance Supplement
• Federal Register Vol. 65, No. 124, Resource Sharing for Workforce Investment Act
  One-Stop Centers
• Generally Accepted Accounting Procedures (GAAP)
• Washington State Employment Security Department Policy and Procedures
• Washington State Office of Financial Management Policy and Procedures

DIRECT INQUIRIES TO
Bob Isom
Employment Security Department
Employment and Training Division, WIA Title I-B
P.O. Box 9046, MS 6000
Olympia, WA 98507-9046
E-Mail: bisom@esd.wa.gov
Telephone: (360) 438-4779
FAX: (360) 438-3174