WIOA Title I-A & I-B Policy & Procedure Manual

Work Authorization Verification Requirements

Effective Date: TBD

Career planners may deliver many WIOA Title I services to participants without verifying a participant is eligible to work in the United States (i.e., having "work authorization").¹ Based on Title 1 of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), there are specific services that cannot be provided to participants without verifying work authorization. The following chart lists the ASSET services and, for each service, identifies if work authorization verification using I-9 acceptable documents is required before the participant receives that service.

*Note: Once a participant has self-attested to being eligible to work in the United States, program funded supportive services may be used to help obtain certain documents, such as a driver's license and/or a social security card, that are used to verify work authorization. See Form I-9 for acceptable documents used to validate whether a participant has work authorization. Costs for program-funded supportive services must be reasonable.

• ¹ TEGL 10-23, pp. 5-8
• ² TEGL 10-23, p. 6-7
• ³ TEGL 10-23, p. 6-7

Reasonable Cost

Effective date: October 10, 2018

Costs are considered reasonable if they are of a nature and amount that would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs. The question of reasonableness is particularly important when the non-federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to:

1. Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the federal award.
2. The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; federal, state, local, tribal, and other laws and regulations; and terms and conditions of the federal award.
3. Market prices for comparable goods or services for the geographic area.
4. Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-federal entity, its employees, where applicable its students or membership, the public at large, and the federal government.
5. Whether the non-federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the federal award's cost. (2 CFR § 200.404)