Workforce Wonkery · Analysis

Issued

WSD16-16 — Allowable Costs and Prior Written Approval

Source + trust record

Source checked as of September 18, 2026. Primary authority: EDD WSD16-16, EDD WSIN25-17, and current Uniform Guidance.

Check result: WSD16-16 remains active California guidance on allowable costs and prior written approval. Current federal adjustments raised the procurement prior-approval threshold referenced by EDD to $10,000. Allowability still depends on necessity, reasonableness, allocability, consistent treatment, documentation, award purpose, and any approval required by the applicable federal, state, or grant-specific rule. This AI-assisted brief does not receive human legal or compliance review. Official sources control.

WDB decision strip

STATUSACTIONPRIMARY OWNERCURRENT TIMINGIMPACT
FINAL · ACTIVEVERIFY ALLOWABILITY + PRIOR APPROVALFiscal + Program LeadershipBefore obligation and reimbursementAllowable costs · Prior approval · Documentation · Grant compliance

The bottom line

Allowability should be resolved before money is committed, not defended after the cost appears in the ledger. Fiscal and program staff should test necessity, reasonableness, allocability, consistency, award purpose, documentation, and any prior-approval requirement before obligation or reimbursement.

Official source: EDD WSD16-16 — Allowable Costs and Prior Written Approval

Allowability starts before money is spent: cost principles, grant purpose, allocation, documentation, and required prior approval all need to line up

WSD16-16 explains allowable costs and circumstances requiring prior written approval for WIOA and other covered workforce grants. The directive remains active, but the current procurement prior-approval threshold is $10,000 rather than the older amount reflected in historical guidance.

At a glance

Issued
February 21, 2017

Revised
October 6, 2017

Current prior-approval threshold
$10,000

Framework
2 CFR Part 200

Executive takeaway

A cost is not allowable simply because the program benefits from it. It must be necessary and reasonable, allocable to the award, consistently treated, adequately documented, permitted by the grant and cost principles, and supported by prior written approval when the applicable rule requires it.

Five questions before committing funds

  1. Is the cost connected to the purpose of this specific grant?
  2. Is the price reasonable and supported?
  3. Can the cost be allocated to the award without shifting another program’s share?
  4. Does local policy and federal/state guidance permit it?
  5. Is prior approval required—and has it been obtained before commitment?

Updated threshold: Current EDD guidance raises the applicable procurement prior-approval threshold from $5,000 to $10,000. Other categories can require prior approval regardless of dollar amount, so review the cost type—not only the price.

Operational considerations for Local Boards

  • Maintain a current prior-approval checklist by cost category.
  • Build approval steps into procurement and payment workflows before purchase orders are issued.
  • Keep EDD approval with the related contract, invoice, and grant file.
  • Train program managers as well as fiscal/procurement staff on allowability.
  • Use current Uniform Guidance for newer awards when federal rules have changed.

Source basis

Primary source: EDD WSD16-16 — Allowable Costs and Prior Written Approval

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