[wiaattorneys] Re: Need Opinion

  • From: "Nancy Meeden" <Nancy.Meeden@xxxxxxxxxxxxxxx>
  • To: <wiaattorneys@xxxxxxxxxxxxx>,<jpomerantz@xxxxxxxxxxx>
  • Date: Thu, 22 Feb 2007 17:44:37 -0500

Jane:

We received questions like this from our local areas last year as folks who 
were impacted by Katrina came to the State. 

The Act and Regulations allows funds to be used for support services, and the 
definition in both is fairly open-ended, defining support services as services 
"such as" transportation, child care, housing, and needs-related payments that 
are necessary to enable an individual to participate in WIA activities.  With 
the words "such as" as part of the definition, it does not appear to limit 
support services to only those items listed in the Act and Regulations. 

We referred our local staff  to review 20 CFR 663.800 which require Local 
Boards to develop policies regarding support services.  

Also, we recommended reviewing both A-87 and A-122 as you suggested.  Both 
circulars prohibit expenditures for "fines and penalties," so they should 
ensure that the paperwork indicates that the funds used for expungement were 
not used for payment of a fine.  

Nancy F. Meeden
Legal Services Manager
Career Development Services 
Georgia Department of Labor 
148 Andrew Young International Blvd., Suite 650
Atlanta, Georgia  30303
(404) 232-3797, phone
(404) 232-3791, fax

>>> "Pomerantz, Jane C. (GC-LI)" <jpomerantz@xxxxxxxxxxx> 2/21/2007 11:51:43 AM 
>>> >>>
Hi everybody

Can a Title I WIA operator and/or state use WIA funds to pay for the
costs (about $150) to expunge a person's felony record? We looked at OMB
Circular A-122 and there is nothing there. Any other ideas or opinions??

Thanks JP

Jane C. Pomerantz
Deputy Chief Counsel
Department of Labor & Industry
Phone: 717-787-4186
Fax:     717-787-1303

Wisdom is knowing the right road to take.
Integrity is taking it.
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