TEGL 11-25 resolves a recurring workforce-system myth: federal workforce dollars can support advertising and public-relations activity when the outreach is tied to the award and meets the federal cost principles. The right question is not “is this marketing?” It is “does this cost advance the funded program, and can we defend the allocation?”
Source + trust record
Source checked as of September 18, 2026. Primary authority: USDOL TEGL 11-25.
Check result: TEGL 11-25 is active, continuing federal guidance issued May 19, 2026. It clarifies that outreach can be an allowable use of WIOA, AEFLA, Perkins V, and certain competitive-grant funds when costs meet the applicable federal cost principles and award terms. Allowability remains award-specific, and procurement, allocation, internal-control, and branding requirements still apply. This AI-assisted brief does not receive human legal or compliance review. Official sources control.
WDB decision strip
| Status | Action | Primary owner | Timing | Impact |
|---|---|---|---|---|
| ACTIVE FEDERAL GUIDANCE | REVIEW OUTREACH PRACTICE | Program + Fiscal + Communications Leadership | Standing federal grant requirement | Outreach · Recruitment · Employer engagement · Allowable costs |
The bottom line
Outreach can be an allowable program cost when the federal award actually benefits.
DOL identifies advertising and public-relations activities that may be charged to federal workforce grants when they are necessary, reasonable, allocable, consistent with award terms and the Uniform Guidance, and tied to the funded program or service. Outreach that mainly promotes the organization’s brand or prestige is a different proposition.
The four-question approval screen
| Question | What a defensible answer shows |
|---|---|
| Necessary? | The outreach helps accomplish recruitment, enrollment, employer engagement, service delivery, or another objective of the award. |
| Reasonable? | The scale and price are prudent for the audience, channel, and expected benefit. |
| Allocable? | The charged grant receives benefit; if several programs benefit, shared costs are distributed according to relative benefit. |
| Proper purpose? | The communication promotes the federally funded activity or service rather than general organizational image. |
Examples DOL says may be allowable
| Advertising | Public relations / engagement |
|---|---|
| Print, digital, radio, social media, billboards/signage, text applications, QR codes, and other paid communication promoting grant services. | Job/career/community fairs, Rapid Response events, mobile or satellite one-stops, community access points, career days, podcasts, interviews, and similar public-facing activity. |
Shared AJCC outreach can be infrastructure
TEGL 11-25 specifically recognizes that AJCC partners may address shared advertising and public-relations costs through MOUs and Infrastructure Funding Agreements. That creates room for a common customer-facing workforce-system campaign when multiple programs benefit. The fiscal record still has to show the benefit and allocation to each participating award.
The approval record to keep
| Document | What it should show |
|---|---|
| Purpose | Which funded service, population, employer need, or outcome the outreach advances. |
| Audience + channel | Who is being reached and why the medium is appropriate. |
| Cost basis | Why the price is reasonable and consistent with procurement/internal controls. |
| Allocation | Which grants benefit and how shared costs are distributed. |
| Award check | Any restrictions in the grant, state policy, MOU/IFA, or subrecipient agreement. |
| Result | Inquiries, enrollments, employer leads, referrals, attendance, or another intended outcome where measurable. |
Operational considerations for WDBs
- Review local fiscal guidance that says federal funds can never be used for “marketing” and correct overbroad language.
- Create a simple pre-approval form using the four-question screen.
- Use shared AJCC outreach when it creates a better customer experience and a defensible cost allocation.
- Build outreach into grant design instead of waiting until enrollment is below target.
- Flow the same standards to subrecipients and contractors responsible for outreach.
Watch out
- Allowability is award-specific; an example in TEGL 11-25 is not automatic approval of every cost.
- Do not charge one program for outreach that primarily benefits another.
- Do not use federal program funds for lobbying, partisan activity, or general image-building.
- Do not skip procurement, internal controls, or required public-communications language.
Source authority
Primary source: USDOL TEGL 11-25 — Clarifying Allowable Outreach Activities for Federal Formula and Competitive Grants.
Interpretation note: TEGL 11-25 applies the Uniform Guidance cost principles, including 2 CFR 200.421, together with award-specific terms and other applicable rules. The approval record above is a WPU implementation aid. Source checked September 16, 2026.