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1. What were the changes in the VSC Update?

• County dashboards were added for all VSC staff.
• Reminder emails will be sent every 2 days until the staff member addresses the initial outreach.
• Weekly reminder emails will follow after the initial outreach is conducted.
• Reminder emails will be sent to close out requests before the 30-day period has passed.

2. Is the SAVE button being removed?

• No, the save button remains at the staff updates stage. 

3. Should the bulk of our comments be in the initial outreach or in the update?

• The interactions between local office staff and customers should be in AOSOS as this is the state’s case management system.

4. Can the subject line of the email sent to administrators differ from the subject line of the email sent to general staff?

Yes, as part of this version update, the subject lines differ as follows:

• Administrators: "You have a new career services request to assign."
• Staff: "You have a new career services request to review."

Note: Administrators should not receive reminder emails after assigning the request.

5. Why can’t the person who assigned a request change it afterward?

• To reassign a request, please contact your designated technical assistant liaison. 

6. Can the Business Services team, DVR, or WIOA be incorporated into the VSC to service customers sooner?

• The VSC is designed for individuals to filter through ES staff for vetting before referrals are made to other local partners.  

7. Do requests close automatically after 30 days? Should staff let them close or follow up?

• The system automatically closes requests after 30 days. ES staff should make every effort to assist individuals and close out cases before the 30-day mark.

8. Should we let records for customers who do not respond close out automatically after 30 days?

• Local offices should document in AOSOS that several attempts to contact the individual were made. If after these attempts the person does not respond, the requests should be closed and staff should not wait for the 30-day window. If the customer responds after the VSC record was closed, services can continue and they should be documented in AOSOS. 

9. Should VSC requests be addressed within 48 hours?

• Yes, all requests should be addressed within 48 hours.

10. Employees who are not assigned to my office are still assigned to my dashboard.

• This issue arises due to individuals using their own "User's Views." They should use the county's common views, as each county has its own dashboard.

11. When other offices reassign requests, the order on the county dashboard reflects when the customer was assigned, making it difficult to track reassigned requests. How can we improve this issue?

• The dashboard can be adjusted to show requests based on when they were last updated, rather than when they were assigned. Filtering is also recommended to increase the number of visible requests on the page. 

12. Can users delete dashboard tabs created prior to the update?

• Yes. Click on the grid action icon in the top right (three lines with three dots), select "Manage Views," and click the trash can icon next to the view you want to delete. Confirm the deletion.

13. Why doesn’t the county dashboard show the Career Services option?

• Click on "Common Views" to see the Career Services option.

14. What should we do if someone is out of office (OOO) for an extended period?

• Use Workflow Delegation (top right corner) to forward requests:
• Click "Add"
• Select Date Range
• Select Destination User

Note: Ensure you assign someone with the same level of approval as you. See the Workflow Delegation User Guide. 

15. Which account should I use to see the VSC county dashboard? 
You should use your own account, not the county account used for RESEA.

16. Can we implement a “back button” on requests?
We currently do not have this capability on SimpliGov due to specific admin functions, which could cause other issues. We suggest updating AOSOS when you cannot access the request on SimpliGov.

17. How should we handle duplicate requests?
Local offices should address all the customers’ needs to reduce duplicate requests.  In the conversations while providing services, local staff should explain that if a request is resubmitted, it will land with them again. Additionally, all interactions with customers should be documented in AOSOS which will assist staff in determining whether the requests are duplicates. 

18. Is there a service we provide for “Job Placement,” and why is this an option customers can request?
Per leadership, this was a metric negotiated with USDOL several years ago. Until this changes with USDOL, we need to keep this option on VSC SimpliGov.

19. What is our policy with VSC requests that are incomplete, such as missing mailing or email addresses?
Local staff should make every effort to contact the individual. If you are unable to due to missing key information, state this on the VSC request and close out the request.

20. VSC Emails are being sent to the Clutter category. What should we do?
Please mark the email address as a safe sender: NoReply-Workforce-VSC@dol.nj.gov. This should prevent emails from being sent to Clutter.

21. Who do we contact if we need VSC help or have questions moving forward?
For dashboard technical issues, submit a request through ServiceNow. For programming-related questions and to reassign a request, contact your designated technical assistant liaison or email wioapod@dol.nj.gov.

View the training recording here. 

Achievement Objectives

Q 1. When should an achievement objective be created?
The AOSOS Technical Guide specifies that individual achievement objectives must be created when a planned action or service is entered in an IEP or ISS. When an actual funded service is entered in AOSOS, it should be connected to a specific achievement objective that was created and entered as a planned service. Achievement Objectives are related to the plan that is established based on assessment results and funded services reflect the actual engagement of participants (Page 9 & 16).

AOSOS-Entry (Services, Outcomes)

Q 2. Should we enter services individually or one service as a blanket?
The AOSOS Technical Guide specifies that if a service provider offers more than one service type, multiple services and service IDs must be created for each service. For example, if ABC Youth Corps offers work experience, adult mentoring, and financial literacy, 3 unique service IDs must be created and connected to the appropriate Service Seeker Type (SST) (Page 16). Please note that when you create new service entries in the Provider Module, the WIOA Eligible Status will show as “Not Approved”; however, this will not impact reporting for USDOL and NJDOL. ETPL status is tracked through other monitoring processes.

Q 3. Which activity should be used to reflect ongoing services?
There’s no singular activity in AOSOS that can reflect ongoing services. The AOSOS Technical Guide outlines the different activities and or services that can be used when customers continue to engage in specific services. Local areas should minimize entering activities or services that do not offer specific details about the nature of ongoing services, for example Local Office Contact. If you find that there is not an activity or service that reflects a specific service offered, you may always reach out to our POD team to inquire about adding additional activity or service codes to AOSOS. For example, ongoing assessment such as retesting of literacy or math skills could be reflected by using the Literacy Test and/or Math Test activity in AOSOS. For more examples see AOSOS Guide, (Table 10, Page 18) or NJWIN (Page 4).

Q 4. Does every counseling session need a counseling statement? Or can a comment suffice?
The AOSOS Technical Guide specifies the guidelines for using counseling statements. Counseling statements must be used to record confidential and sensitive information related to assessment and eligibility which may arise at different points of time during an individual’s active service period. For the most part, when counselors record general career assessments and expressed training interests unrelated to training eligibility and justification may be noted in Comp Assess comments (Page 6).

Q 5. Why is a single counseling statement necessary?
The AOSOS Technical Guide specifies that a counseling statement is only necessary to record confidential and sensitive information related to assessment and eligibility. A single counseling statement must be used to record all sensitive information related to an individual’s ongoing engagement around a particular IEP or ISS. Please edit the same Counseling Statement when including new confidential information related to an individual’s ongoing engagement. All new entries to an edited statement must include the date of entry and be entered at the top of the Counseling Statement so that information is sequential. Counselors should not create new Counseling Statements each time they enter new information (Page 6).

Q 6. What is the difference between counseling statements, comp assess comments, and customer detail comments?
Table 3 or page 6 in the AOSOS Technical Guide provides the guidelines for using counseling statements and comment sections in AOSOS to document details around an individual’s engagement in services. Counseling statements must be used to record confidential and sensitive information related to assessment and eligibility.

Comp Assess Comments must be used to record most information related to assessment activities and results, particularly details about academic and occupational assessments.

Additional details related to engagement in job assistance activities and service plans and engagement must be entered in the joint Customer Detail/Service Comments tabs. Comments entered in either tab show up in one stream of comments. This includes information related to IEP/ISS development, engagement in services, identification of additional supportive service needs, training and employment outcomes, and follow-up services.

Q 7. What is the difference between the career guidance and counseling activities? Are they interchangeable?
AOSOS includes definitions of these two activities. Career Guidance is defined as “Services which include the provision of information, materials, suggestions, or advice which are intended to assist the job seeker in making occupation or career decisions.” Counseling – Individual and Career Planning is defined as “A meeting in which an employment counselor or counselor trainee provides ongoing or one-time assistance to help a customer gain a better understanding of themselves so they can more realistically choose or change an occupation or make a suitable job adjustment.” We are encouraging local areas to utilize the Counseling – Individual and Career Planning specifically when engaging in IEP and ISS development and conversations.

Q 8. What activity should we use to indicate monitoring a customer’s progression through training?
Depending on the nature of the engagement, Counseling – Individual and Career Planning, Comprehensive Guidance and Counseling (in the case of youth services), and Case Management all offer specific activities or services that can be entered to indicate ongoing support and connection with an individual throughout their service engagement. We encourage local areas to make these points of monitoring meaningful interactions for ensuring support and success of participants. More details about this can be found on page 17 of the guide.

Q 9. Is it okay to use the EEO notification activity in AOSOS under the RESEA folder for the adult, dislocated worker, and youth populations?
Use the EEO Notification activity under Labor Exchange.

Q 10. Do we select the EEO activity in AOSOS when a customer receives an EEO form which notifies them of their rights? At what stage does the EEO get presented to a customer?
Yes. The EEO activity records the provision of the EEO forms (Your Right to File A Complaint, Complaint Procedures, and Acknowledgement Form) which should be handed out and signed at eligibility determination stage. (NJWIN 12-16(A) Complaint Procedures).

Follow-up Services (A/DW/Y)

Q 11. What’s the difference between follow-up as a service and follow-up as an activity?
The AOSOS Technical Guide highlights that follow-up services refers to specific engagements after a customer has exited from Title I services Exit and Follow-up Policy (Final).pdf. In other words, a funded follow-up service should only be entered if a participant engaged with a staff member and received an actual allowable follow-up service. If follow-up was attempted, but no connection or specific follow-up service was offered, staff must use the Follow Up Attempted activity in AOSOS. A detailed comment should be entered regardless if the follow-up was successful or unsuccessful (Page 24-25).

Q 12. What does no-gap mean when providing follow-up services?
NJ’s follow up policy expands the 12-month follow-up requirement after exit to all Adult and Dislocated Worker participants in New Jersey, whether or not the individual is placed in unsubsidized employment or training. In other words, Adult, Dislocated Worker, and Youth
participants must all have access to follow-up support for at least 12 months after exit and no gap should exist between exit and the beginning of follow-up services. A participant’s follow-up period may extend beyond a 12-month period if needed, especially if a gap exists between exit and job placement.

Q 13. How do we note in AOSOS that a youth has declined follow-up services in AOSOS? Can a comment suffice?
For adults, dislocated workers, and youth, follow-up service may be discontinued if the participant indicates that they no longer need or want the follow-up contact. The participant must send an email or a writing indicating the participant’s desire not to be contacted further. Service provider staff shall not solicit this request. The individual may opt out of receiving follow- up at any point during the program or during the follow-up period. Opting out must be documented in a comment in AOSOS, as well as in the paper file. Opting out must be an informed and active choice of the participant that is based on full knowledge of the supports and services to which an individual has access. In cases, where an individual verbally expresses a choice to discontinue and is unwilling to submit written notice, this must be documented in a comment in AOSOS. (WD-PY21-5, Placement, Exit, and Follow-up Procedures Pg. 9-10)

Q 14. Do you want us to follow up all 12 months with no response? Or is there a cut off? For example, 4 months in a row with no answer. Can we stop follow up? Is this something that is determined locally?
Page 10 of the Placement, Exit and Follow-up Policy states if “no contact is made within the first six months, follow-up services may be terminated”. However, local areas should develop their own local follow-up policy that highlights specific information about follow-up procedures and specifically expectations regarding follow-up attempts that offers a reasonable standard for attempting to support and offer ongoing connection to exited participants.

Q 15. Can you clarify the follow up for Adult/Dislocated: Which one is quarterly vs monthly?
Follow-up services must be attempted quarterly for Adult/DW participants and monthly for Youth participants. When these attempts result in service, a same day follow-up service must be entered. (AOSOS Technical Guide for Title I Services Delivery pg. 24)

Q 16. If follow up is missed for more than a month, would it reset the process?
No. If follow-up was unsuccessful for a particular month, the “follow-up attempted” activity should be taken and a comment explaining the attempt should follow for Adults, DWs, and Youth. “Missing” follow up for a month would not “reset” anything. Follow-up for Adult/DW is recommended to be done on a quarterly basis; therefore, if a follow-up attempt was missed for a month, it could be tried again within that quarter. (WD-PY21-5, Placement, Exit, and Follow-up procedures).

Q 17. Will a new Achievement Objective be necessary for each successful Follow-up contact, especially if supportive services are provided post-exit?
Local areas have some flexibility with this. Local area staff can connect various follow-up services to one follow-up achievement objective or multiple achievement objectives, whatever works best for your staff. The guidance is in place to ensure that information about follow up services is documented and easy to find via the achievement objectives tab in the Outcomes/Status field, as well as in the Comments sections of AOSOS. Clear information about follow-up services is the primary focus of this guidance.

IEP (Process, Requirements)

Q 18. I did not see/hear any mention of entering in an Individual Employment Plan activity, is this something that is still required in addition to the other activities that were mentioned?
Yes, an employment plan activity should be taken during the plan development phase of service delivery (creating and updating IEPs and ISSs) as outlined in Table 4 of pg. 9 of the AOSOS Technical Guide for Title I Service Delivery. If you’re also reviewing assessment results with a participant while developing an IEP or ISS you should also use the Counseling – Individual & Career Planning activity.

WIOA Post-training Activities

Q 19. How do we continue to provide placement services during follow-up without causing common measures? If we continue to provide supports, how do we note these services in AOSOS?
Ideally, placement or post training services should happen immediately after training or work experience completion before exit and as part of the individual’s period of participation. This would not trigger re-enrollment.

If during the follow-up period, general placement/employment information discussions take place, i.e., verification of credentials or employment, this does not count as follow-up. (WD-PY21-5, Placement, Exit, and Follow-up Procedures). However, more specific supports helping to coach and support the connection or retention of an individual to employment, or in making referrals to additional supports – see page 8 of WD-PY21-5 for a list of activities – can and should be entered as follow-up services in the services module. Please note, many activities, if entered within the 90-day soft exit period will prolong the participation period, but a general follow-up service designated as a follow-up service in the Services module will not prolong the participation period.

Supportive services can be provided to WIOA title I Youth during program participation and during follow-up services. An achievement objective detailing the nature of the support must be created. Supportive Service element must be funded, and a comment should summarize the nature of the support.

However, supportive services are only available to active Adult/Dislocated Worker WIOA participants as outlined in TEGL 19-16. Adult/Dislocated Worker participants identified as needing ongoing supportive services must still be participating in career services (other than follow-up), training activities, or both to continue to receive supportive services.

Q 20. We would also like to know specifically, what needs to be captured in AOSOS if we are offering job placement assistance.
Table 10 of the AOSOS Technical Guide for Service Delivery provides an overview of the activities that can be used job placement assistance such as Resume Writing Workshop, Job-Search Planning, and Job Development Contact (page 18).

Other

Q 21. What’s the difference between Career Assessment and Supportive Services Assessment?
Career and/or Occupational assessments offer opportunities for individuals to explore a number of different attributes that may influence their potential success and satisfaction with different career options and work environments. Career and/or Occupational assessment help participants to assess and reflect on: (1) prior work experience, (2) employability, (3) interests, (4) values, and (5) aptitudes.

Supportive service assessments include an evaluation of additional barriers to employment, beyond barriers specific to academic or occupational skill levels. This assessment focuses on the circumstances that may hinder success in education or employment opportunities, including specific developmental needs. Assessment Technical Assistance Guide.pdf 

View the training recording here. 

1. What is the process for interstate claimants to apply for ABT?
Interstate claimants who file through another state but have New Jersey residency must have an active New Jersey Unemployment Insurance (UI) claim to qualify for ABT; interstate residents collecting benefits from another state are not eligible and should contact WIOAPOD@dol.nj.gov if their local office is designated as #999 for an assessment.​

2. Is it required for the claimant to have a NJ UI claim or is NJ residency sufficient for an out-of-state claim?
It is not sufficient to be a New Jersey resident with an out‑of‑state UI claim; ABT is strictly limited to claimants with an active NJ UI claim.​

3.  What happens if someone receives ABT benefits for weeks they aren’t entitled to receive?
If a claimant receives ABT funds for weeks later found ineligible, it is treated as overpayment under N.J.A.C. 12:17‑14, requiring repayment to the NJDOL.

4. How long does it take to receive ABT benefits from the time a claimant applies?
Processing time for ABT issuance following approval varies.  They are processed in the order that they are submitted.

5. Is it possible to receive an ABT partial claim?
ABT extensions are not available to individuals collecting a partial UI claim, as the program is designed for claimants who are unemployed and in full‑time training.​

6. How is fulltime training determined for a claimant that is taking online classes?
For online or hybrid classes, “full‑time training” is defined as 20 supervised hours per week (classroom equivalent), or for degree programs, 12 undergraduate credits or 9 graduate credits per semester. Training formats must meet these hourly requirements, even if self‑paced or virtual.​

7. If UI approves my training, does it mean that ABT is automatically approved?
Approval of training by UI does not automatically guarantee ABT approval; ABT eligibility also requires WDP counselor verification, development of an Individual Employment Plan, and validation that training meets statutory conditions.​

8. Is it possible to approve training for ABT if the vendor/provider isn’t listed on the ETPL?
Generally, training must be provided by an Eligible Training Provider (ETP) listed on the ETPL, but an exception exists for remedial training if documented as part of an approved plan leading to employment.​

9. Is it possible to approve ABT for training that doesn’t appear on the Labor Demand Occupation list?
ABT approval requires training associated with a high‑labor‑demand occupation; exceptions are rarely granted and must be justified in the Individual Employment Plan by demonstrating clear job placement potential even outside the Demand Occupation List.​

10. Is it possible to file a partial ABT claim?
A claimant cannot file a partial claim under ABT; eligibility is based on enrollment in full‑time, approved training and full separation from employment.​

11. Can a claimant qualify for ABT if they have a claim that was shorter than the maximum 26-week claim?
Yes, any valid and active UI claim qualifies for ABT, regardless of the number of weeks the claimant was originally eligible to receive benefits.

12. How old can an active claim be to qualify for current ABT benefits?
The age of the most recent claim is not a determining factor, provided it was an NJ valid UI claim.

13. Will LO8V provide access to all of the screens needed to do an ABT assessment?
Yes, LO8V access allows for the separation and confirmation of a valid claim.

14. Is Wage date available through LO8V access?
No, but ABT isn’t determined by wage data.

View the training recording here. 

Q: Does MSG automatically change depending on a better Post test score?
A: Tests such as the CASAS are entered into the Test Tab in NextGen and can capture Education Functioning Level (EFL) Gains based on improvement between a pre-test and post-test.

Q: What if someone is not "enrolled in education" because their course has ended, but they study for a while after the end date and pass a credential exam a few months after training, such as a PMP certification?  How can we ensure credit for these?
A: Once an individual is enrolled in an education course, they are included in the measurable skill gains denominator. If their course has ended and they pass a credential exam a few months later, a skills gain can be captured if the examination took place during the same program year.

Q: Can we go back to the test scores? Does OSOS use the most recent test scores for the measure or the "best" scores recorded?
A: AOSOS uses the most recent test scores for the measure.

View the training video: 

• Part 1
• Part 2

Q: Can ariel be an in-school youth with hardships and individual under snap?
A: Ariel’s scenario is an in-school youth who is not low-income. This scenario was posed with the WIOA Youth program’s exception and limitation rules in mind.

All in-school youth must be low-income. However, there is a 5% limitation rule that allows up to 5% of in-school youth served in a local area to not be low-income. So, in Ariel’s case, who is a parenting youth, he/she could be served using this limitation.

Q: Can a person register for selective service 6 months prior to 18?
A: Yes, SSS will hold registration until the person turns 18. However, as a general requirement, Men born on or after January 1, 1960 are required to register with Selective Service within 30 days of their 18th birthday (i.e. 30 days before or 30 days after their birthday.) TEGL 11-11 Change 2

Q:  Can you elaborate on why self-attestation isn't acceptable for victim of human trafficking? What docs would be acceptable?
Because victims of trafficking can be included in the groups of individuals authorized to work in the United States, said authorization to work cannot be self-attested.

Work Authorization – Victims must meet certain requirements, and only a federal law enforcement agency (such as ICE or the FBI) may request Continued Presence for an individual. Those granted Continued Presence are eligible to apply for employment authorization as well as federal services and benefits.

The U.S. Department of Health and Human Services (DHHS) allows victims of Human Trafficking to apply for the same benefits and services as refugees. The DHHS also issues certification documents for eligible individuals.

HHS issues a Certification Letter after notification from the U.S. Department of Homeland Security (DHS) granting a person Continued Presence, or a T visa, or that a bona fide T visa application has not been denied. Foreign victims of a severe form of trafficking under 18 years of age do not need to be certified to receive benefits and services under HHS.

Documents can include:
T-visa, U-visa, Continued Presence Certification Letter issued by Department of Health & Human Services after approval by Center for Countering Human Trafficking (CCHT).

Sources:
otip_fact_sheet_certification.pdf  continued-presence.pdf 

Q: Is there a certain website we can use to see what training programs are eligible for Pell grants?
A: Federal Pell Grants usually are awarded only to undergraduate students who display exceptional financial need and have not earned a bachelor's, graduate, or professional degree. Federal Pell Grants | Federal Student Aid

In addition, our ETPL (NJ Training Explorer) will allow you to search for training programs that may be Pell eligible.

Tuition Assistance | Support Resources | My Career NJ

Q: ISY, Captive Audience, has IEP and we may use school testing, but what about SS#'s, do we need it or could the parent write it on the paperwork until we get the final copy.
A: SSNs are not required to receive WIOA Title I services. While grantees must request an individual’s SSN for performance reporting purposes, grantees cannot deny services if an individual chooses not to share it.

Source: TEGL 10-23 (Accessible PDF).pdf (page 3)

Q1. What is the Stevens Amendment?
Since 1989, the United States Department of Labor’s (DOL) annual appropriation has included a provision known as the Stevens Amendment. Its purpose is to ensure transparency and accountability in federal spending. This provision requires the recipients of DOL grants and cooperative agreements to acknowledge federal funding when publicly discussing any projects or programs that DOL funded through its annual appropriation. For fiscal year 2021, this provision appeared in section 505 of division H of Public Law 116-260.

Q2. What does the Stevens Amendment require?
The text of the amendment says:

When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects or programs funded in whole or in part with Federal money, all grantees receiving Federal funds included in this act, shall clearly state—

(1) the percentage of the total costs of the program or project which will be financed with Federal money;
(2) the dollar amount of Federal funds for the project or program; and
(3) percentage and dollar amount of the total costs of the project or program that will be financed by non-governmental sources.

When enforcing this requirement, Veterans’ Employment and Training Service (VETS) will make the following interpretations and assumptions:

• The disclosures required by the Stevens Amendment apply to all public materials describing projects or programs funded through the DOL annual appropriation, not just printed materials.
• “Non-governmental sources” means any funding source other than the Federal Government. In this document, we use the term “non-federal funds” or “non-federal sources” for clarity.
• The Stevens Amendment does not require a disclosure of the cost of creating or issuing the particular statement, website, or other documents subject to the disclosure. It only requires disclosure of the total funding for the relevant project or program (e.g., the Jobs for Veterans’ State Grant (JVSG) program in the state) that is described.

Q3. What kinds of documents or locations commonly lack the required Stevens Amendment disclosure?
Based on an informal review of publicly available information, some examples of documents and statements that commonly lack the Stevens Amendment disclosure statement, due to being overlooked, include:

• State Workforce Agency (SWA) Requests for Proposals (RFPs)
• SWA websites
• SWA outreach materials (posters, flyers, brochures, resource guides, etc.) advertising services available at American Job Centers (AJCs)
• Marketing materials advertising AJC services and programs
• Press releases and other public statements
• Social media posts referencing SWA programs, services, grants, etc.
• Bid solicitations

Q4. What form should the Stevens Amendment disclosure statement take?
The general structure can take this form:

The [project/ program] is supported by the [federal agency]. A total of $[amount], or [percentage] percent of [project/program] [is/ will be] financed with federal funds, and $[amount], or [percentage] percent [is/will be] funded by other sources.

For example:

Montana’s Jobs for Veterans State Grant program is supported by the U.S. Department of Labor. A total of $900,000, or 90 percent, of the program is financed with federal funds, and $100,000, or 10 percent, is funded by other sources.

Alternatively, if the program or project is solely financed by the Federal Government:

Florida’s Jobs for Veterans State Grant program is 100 percent funded by the U.S. Department of Labor through awards totaling $15,000,000.

If a project or program has multiple funding sources, each award does not need to be listed separately. For example, documents or websites in many states generally describe programs for veterans that JVSG (through DOL-VETS) and the Wagner-Peyser Employment Service (through DOL-Employment and Training Administration (ETA)) fund.

For example:

The State of Utah’s veteran employment program is federally funded with $8,000,000 (80 percent). Additionally, 20 percent ($2,000,000) is financed by non-federal sources.

Q5. Can you provide examples of disclosure statements that would not fully meet the requirements?
The following examples do not meet the Stevens Amendment disclosure statement requirement:

• “Disclosure of Federal Participation — Projects or programs funded in whole or in part with Federal grant money must credit the federal government for the federal government's portion of the financial support. This web page citation informs the public that the use of Federal dollars in meeting the Stevens Amendment requirement. Staff development opportunities, resource purchases, equipment and personnel have been funded in whole or in part with Federal entitlement dollars.”
  • This statement does not contain the federal funding entity, the amount and percentage of funds from the federal source, or the funding and percentage that any non-federal entities provided.
• “XXX is funded through the Governor’s Emergency Education Relief fund as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Workforce Innovation and Opportunity Act (WIOA) funding.”
  • This statement does not contain the federal funding, amount, percentage of funds from federal source(s), or funding and percentage amounts (if any) that non-federal entities provided
• “Proposed Sub award Amount: The One-Stop Operator will be funded as a WIOA Title I sub award. For planning purposes, bidders should estimate WIOA funding of up to $150,000 for this RFP.
  • This statement does not contain the federally provided percentage of funds, the total dollar amount of federal funds supporting the project or program, or the funding and percentage amounts (if any) non-federal entities provided.

Q6. What if a solicitation spans multiple years?
The Stevens Amendment does not specify whether grantees should disclose their annual award amount or cumulative award amount. We recommend using the annual award amount, i.e., the amount of federal funding the grantee received for the budget period and not the longer project period.

Q7. Is the Stevens Amendment language required in financial or non-financial contracts?
Contracts do not require the Stevens Amendment disclosure statement. The disclosure is necessary only when issuing statements, press releases, RFPs, bid solicitations, and other publicly available documents describing projects or programs funded in whole or in part with federal money. Grantees receiving federal funds, including those from state and local governments, must clearly state the following in the funding disclosure notice:

• The total dollar amount of federal funds supporting the specific project or program;
• The percentage of total costs that federal funds financed; and
• The percentage and dollar amount of the total costs non-federal sources (if any) financed.

Q8. Which amount should be included in the disclosure statement?
Recipients must provide the total amount of federal funds that support the project or program and the percentage of total costs federal funds financed. Because the Stevens Amendment does not specify whether to use the current year’s annual amount allotted, the amount received during the current year (i.e., incremental funding), or the cumulative amount (i.e., the total amount for all combined awards within the period of performance) recipients may choose. VETS recommends using the current fiscal year’s annual award amount received for the budget period. Whichever method is used, the recipient should consistently use that method for all Stevens Amendment disclosures across all programs.

Q9. What types of press releases are subject to the Stevens Amendment?
Press releases describing projects or programs funded in whole or in part with federal money must include the disclosure statement. Because AJCs are funded extensively with federal funds, all AJC press releases require careful review. Also, if those communications describe a project or program that federal funds subject to the Stevens Amendment financed in whole or in part, then the press release must include the required funding disclosures.

Q10. Does the disclosure statement need to be on organizational websites?
Organizational websites describing projects or programs that federal funds subject to the Stevens Amendment funded in whole or in part must contain the disclosure statement.

Q11. Is the Stevens Amendment disclosure required on every page of the document or website?
No, the Stevens Amendment disclosure is not required on every page of the document or website, but at least one page must contain the disclosure statement

Q12. Within any communication, what language is considered “describing projects or programs”?
Any communication made in furtherance of accomplishing the goals of a federal project or program for which the grantee has an award is a description of projects or programs.

Q13. Which communications are included in “other documents”?
In the Stevens Amendment, “other documents” is any communication including but not limited to: public statements, social media posts, toolkits, resource guides, websites, and visual presentations. For example, an emailed newsletter intended for the public that describes a federally funded program requires the disclosure statement. The following list includes some examples of documents or other publications that may describe a project or program that federal money funds in whole or in part:

• Bids for solicitations
• Blogs/vlogs
• Brochures
• E-mail blasts
• Manuals
• Press releases
• Promotional materials (e.g., fliers, advertisements)
• Requests for proposals (e.g., supplemental and continuation proposals)
• Resource guides
• Those documents that include statements about the program or project
• Toolkits
• Visual presentations (e.g., PowerPoint presentations)
• Websites

Q14. Would a tagline like this suffice as a disclosure statement? “Grantee of xxxxx is fully funded by federal funds through direct awards and sub-awards.”
No. The Stevens Amendment requires both a dollar amount and the percentage (as applicable) of federal funds provided for the project or program.

Q15. We use social media posts to announce services, training programs, etc. Is a disclosure statement required for social media posts? If so, does it need to be in the body of the item or can it be in a tagline?
Yes, a disclosure statement is required for social media posts. The statement does not need to be in a specific part of the communication; it only needs to clearly state the required information.

Q16. Some social media platforms, like Twitter, have a limited number of characters. How can we include the disclosure statement in this circumstance?
When it is not practical to put the disclosure statement within the electronic communication, a hyperlink to the statement is sufficient.

Q17. Can the statement include a link on digital or printed material in place of a dollar amount while including the rest of the required information?
If the material is digital, a hyperlink is fine. Because it is not possible to hyperlink on a printed document, including one would not be sufficient to meet the notification requirement

Q18. On a bid solicitation, the cost is not known in advance. What amount should we then include in the disclosure statement?
The amount in the disclosure statement is not the amount for the specific item that is the subject of the communication (such as a bid solicitation, in this example). Use the amount and percentage, as applicable, for the entire project or program.

Q19. Is a disclosure statement required on communications related to indirect funding, such as an RFP for payroll processing?
No. A disclosure statement is only required for activities that further the goals of a federal project or program. Indirect activities, although federal awards ultimately fund them through the application of an indirect cost rate, do not directly further the goals of a federal project or program.

Q20. Should monitoring for compliance include programmatic reports, fiscal reports, or both?
Both.

Q21. What must grantees of federal funds do to ensure compliance with the Stevens Amendment?
Grantees are encouraged to create a compliance monitoring plan that includes:

• Providing copies of the programmatic and fiscal monitoring reports to the grants compliance specialist to ensure compliance with the Stevens Amendment.
• Requiring Stevens Amendment provisions be listed in all policies, processes, and monitoring procedures.
• Updating grantee financial monitoring tools to ensure this requirement is met.

Q22. What are the penalties for noncompliance?
Although no sanctions are specified for noncompliance, failure to comply could be considered a breach of responsibilities and may result in a corrective action plan; conditions placed on the award; or termination, suspension, or debarment of funds awarded. However, the U.S. House of Representatives recently introduced a bill that, if passed, will penalize noncompliant recipients (The Cost Openness and Spending Transparency Act of 2021).

Q23. We have existing brochures and other printed material documents describing projects or programs funded in whole or in part with federal money that do not include the required statement. Do we need to throw them away?
No. Grantees do not have to throw away materials that do not include a Stevens Amendment disclosure, but you must update documents in future printings to meet the Stevens Amendment requirements; the intention is to come into compliance — not to waste existing resources.

Q24. What are potential audit points?
VETS will audit states’ compliance with the Stevens Amendment in accordance with VPL 02-21 JVSG Triennial Audit Program, or the most recent guidance on this topic. These audits may result in an “area of concern” designation for this triennial cycle. States must submit a formal response to any areas of concern, and then VETS will determine the appropriate remediation steps. Please refer to question 22 for potential sanctions for noncompliance with grant terms and conditions.

Q25. Do Priority of Service posters at AJCs need to include the Stevens Amendment disclosure?
Priority of Service is not a “program” or “project”; it is a law and requirement for states to implement. Therefore, documents (e.g., brochures, posters, websites, etc.) that solely speak to Priority of Service do not require a Stevens Amendment disclosure. However, if the document goes on to list services that are available to veterans that federal funds paid for, then the disclosure is required.

Q26. Where can I go to learn more?

• Public Law 115-31, Division H, Title V, Section 505, page 428
• GAO Report to Congress (March 2021)