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Local Workforce Investment Area LWIA

By Glen Patterson,2014-05-18 04:01
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The purpose of Workforce Investment Act (WIA) oversight and monitoring is to ensure v Increased documentation requirements and/or increased monitoring

Preface

    __________________________________________________________

Introduction

Technical Advisory No. 04-19 issued by the New York State Department of Labor’s Workforce

    Development and Training (WDT) Division, provided clarifying guidance on the roles and responsibilities of the Chief Local Elected Official (CLEO) (or the CLEO’s designated Fiscal Agent) and the Local Workforce Investment Board (LWIB) in conducting financial, program and performance oversight and monitoring in local workforce investment areas. This monitoring guide has been developed by WDT for the Local Workforce Investment Areas (LWIAs) to use as they carry out their oversight and monitoring responsibilities. The LWIAs will be required to use this guide or alternatively, incorporate the elements of this guide into their own work products as they carry out their oversight and monitoring responsibilities.

Technical Assistance

    Helpful information to support the monitoring process can be found through the following websites:

    http://www.doleta.gov/usworkforce Select “Laws and Regulations” to review the Workforce

    Investment Act of 1998 and the WIA Final Rules.

    http://wdr.doleta.gov/directives/ From this website you can review a listing of USDOL, TEGLs

    and TEINs by program year and connect to specific documents.

    http://workforcenewyork.org/ This NYSDOL Web site provides access to informational items by

    selecting Information, Policy Related material, Technical Advisories

    Additionally, staff from WDT will be available to LWIAs to provide technical assistance in the establishment of systems and processes to help bring about compliance with the requirements set forth in Technical Advisory No. 04-19.

Monitoring Purpose and Process

    The purpose of Workforce Investment Act (WIA) oversight and monitoring is to ensure the integrity of the WIA system and WIA funds, to review performance, assess compliance with applicable laws and regulations and identify successful methods and practices that serve to enhance the system as a whole through continuous improvement.

    The monitoring process should be accomplished through a combination of desk and on-site reviews. Desk reviews are used for collecting and analyzing information and to support on-site reviews/monitoring. Desk reviews analyze existing data such as required monthly financial reports, vouchers, contracts, budgets, OSOS data, and prior audits and monitoring reports. The Monitor should gather available, up-to-date, written policy, procedures or other guidance governing the systems, programs and contracts under review. The desk reviews may include telephone and/or e-mail contacts with the entity under review or other entities that may have relevant information that may impact the desk review. The Monitor should be prepared to provide on-site technical assistance as a result of issues disclosed during the desk review process.

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On-site reviews are the fundamental component of monitoring and employ data collection

    techniques using formal monitoring guides. The on-site reviews should be conducted per a monitoring schedule. The on-site review allows for the verification of items contained in the contract or grant agreement or which were identified in the desk review. Additional on-site reviews may also be conducted on an as-needed basis, should issues arise that require immediate attention. The Monitor should be prepared to provide on-site technical assistance during the conduct of an on-site review.

    If the program, financial and performance monitoring functions are to be conducted by separate individuals, it is suggested that where appropriate and possible, the scheduling of the monitoring reviews be a coordinated effort so as to minimize disruption of the operation of the subrecipient.

     Monitoring Scope and Frequency

    The scope and the frequency of the required oversight and monitoring must include the following reviews:

    I. Program

    ? WIA IB Adult (annual)

    ? WIA IB Dislocated Worker (annual)

    ? WIA IB Youth (annual)

    ? Data Validation (annual)

    ? Subrecipient Contract Reviews (Quarterly)

    II. Financial

    ? Financial Management/Cost Allocation Reviews for Subrecipients Reporting by

    MSDCT/MSCR/AER (annual)

    ? Financial Management/Cost Allocation Reviews for Contracted Service Providers

    (annual)

    ? Subrecipient Monitoring (annual)

    ? Procurement (bi-annual)

    ? Property Management (bi-annual)

    ? Desk Reviews of subrecipient expenditure reports (monthly)

III. Performance and Accountability

    ? Performance Outcomes (quarterly)

    ? Service Progression (quarterly)

    ? Service Levels (quarterly)

    ? Activity Levels (quarterly)

    ? Exit Strategy (quarterly)

    ? Analysis of Relationship Between Expenditures and Program Activities (quarterly)

    ? Trend Analysis (quarterly)

    ? Training Providing Transferable Skills (quarterly)

    ? Training Related to Entered Employment (quarterly)

    The frequencies identified above are minimum levels. Factors that influence whether more frequent monitoring is needed include the following:

    ? The dollar amount obligated to the subrecipient

     Preface 2

    ? Subrecipients with prior audit or monitoring findings or history of poor performance

    ? High profile programs or activities

    ? Programs administered by inexperienced subrecipients

    ? Subrecipients that have inexperienced staff or have experienced a change in key staff

    ? Programs where the subrecipient has requested an on-site visit

    ? Subrecipients that have not been visited recently

    ? Type of sub-award (multi-year vs. single year)

    ? Subrecipients that are not financially stable

    ? Subrecipients that have not conformed to terms and conditions of previous awards

    ? Issues identified by the desk reviews that require on-site follow-up

By identifying a review cycle for each subrecipient, the Monitor should be able to draft a rough

    plan of review visits for a full year in advance. By estimating the approximate number of visits

    for the upcoming year, the Monitor can use this figure in computing total workdays needed and

    use this in developing an overall workload analysis. It is neither expected nor even desirable that

    the Monitor actually schedule their review visit dates a year or even several months in advance.

    There are too many variables that will affect the actual scheduling. However, the Monitor

    should be able to develop a working schedule for 2 to 3 months in advance. This working

    schedule should identify which sites they expect to visit and the approximate dates they hope to

    schedule those visits. Actual visit dates are usually set up no more than one month in advance.

Monitoring Procedures

The monitoring procedures and instructions specific to each of the above topics are presented in

    the individual sections of this guide. Review items are presented in two primary formats: items

    with check boxes requiring a “yes,” “no,” or N/A (not applicable) response; and items requiring

    the entry of a numerical or narrative response. Each review section has a space provided for

    comments. Monitors must provide an explanatory comment for any item answered with a “no.” Any other comments are left to the monitor’s discretion. If the monitor determines a

    review item is not applicable; the N/A box must be checked.

Monitoring procedures and instructions that are universal and applicable to all the on-site review

    topics are presented below:

A. Monitoring Review Set Up

    1. Contact the subrecipient to obtain a start date and advise them of the scope of the

    monitoring review.

    2. If requested, prepare and transmit a letter confirming the date and scope of the review

    send it to the subrecipient.

     3. Telephone the subrecipient prior to the start date of visit as a reminder.

     Preface 3

B. Entrance Conference

    1. Arrange for an entrance conference. However, a formal entrance conference is not

    always necessary. The decision to have an entrance conference should be a mutual one

    between the subrecipient and Monitor. Instances where an entrance conference would be

    necessary are:

    a. This is the initial visit

    b. There are major problems with the subrecipient's financial or program systems

    c. An entrance conference is requested by the subrecipient

2. When an entrance conference is held the subrecipient’s Executive Director and

    appropriate staff should attend.

    3. Subjects discussed at an entrance conference may include, but are not limited to:

    a. The purpose of the visit

    b. The procedures to be used by the Monitor

    c. Problems disclosed during prior review visits

    4. Create a record of the meeting in the Entrance/Exit Conference Exhibits included in the

    guides.

C. Sampling Procedures

Transaction testing comprises a significant portion of the on-site review. Since it is rarely cost

    effective to examine all transactions, monitors should consider examining a representative

    sample or cross-section of the items that make up the various classes of transactions. Sampling

    implies gathering evidence to use as a basis for making valid inferences about the characteristics

    of the population as a whole. The characteristics of most concern when conducting monitoring

    are the effectiveness of control procedures, the accuracy of transaction processing, the reliability

    of agency records and systems, and the accuracy of account balances. Important decisions for

    the monitor to make include:

    ? Which population should be tested and for what (population)?

    ? How many items should be included in the sample (sample size)?

    ? Which items should be included (selection)?

    ? What does the sample information tell about the population as a whole (evaluation)?

Taking these factors into consideration, the Monitor can use statistical or non-statistical

    (judgmental) sampling. When used properly, either sampling approach can be effective. The

    advantage of statistical sampling stems from its objectivity, helping the monitor to design

    efficient samples, measure the efficiency of the evidential matter obtained, and evaluate the

    sampling results. Combining statistical sampling with good monitoring judgment generally

    produces a higher-quality monitoring conclusion than using monitoring judgment alone.

It is up to the Monitor to evaluate the individual and situational costs and benefits associated

    with each sampling approach before making a determination on which one to use.

     Preface 4

Whichever sampling method is chosen by the Monitor, the methodology should be clearly

    identified in the Monitor’s work papers. The Monitor must also make judgments about what

    represents a tolerable error rate and what additional work (e.g. increasing the sample size) may

    need to be performed if that rate is exceeded.

D. Technical Assistance

There are no set procedures to follow for providing technical assistance. Each situation is unique.

    The Monitor must determine what is appropriate in the given circumstances. However, it should

    be kept in mind that the act of identifying an issue without accompanying technical assistance in

    the creation and implementation of corrective action results in little improvement. All technical

    assistance given should be documented in the work papers. Any necessary follow-up assistance

    should also be detailed in the work papers.

    E. Exit Conference

     1. An exit conference is to be held at the end of every review visit.

     2. In arranging the time for the exit conference, ensure that the subrecipient’s Executive

    Director and appropriate staff are available to attend.

     3. Subjects discussed at the exit conference may include, but are not limited to:

     a. Findings disclosed during the review

    b. Action taken to resolve prior findings

    c. Required corrective action and timeframes

    d. Technical assistance to be provided by the Monitor

    e. Timeframes for issuance of written report

     4. Open discussions should be encouraged at the meetings.

     5. Create a record of the meeting in the Entrance/Exit Conference Exhibits included in the

    guides.

F. Monitor’s Work Papers

Monitoring work papers record the activities that took place during the monitoring visit and form

    the rationale for the monitoring report. Extensive notes are a necessary part of the review

    process and serve to validate the information collection process. Monitoring work papers should:

     1. Detail the source of the information acquired and conclusions reached.

     2. Document the weaknesses and deficiencies disclosed by the review.

     3. Be complete, timely and fully reflect the review steps taken by the Monitor.

4. Go through a supervisory review process.

5. Be retained for review by the LWIB and/or NYSDOL.

     Preface 5

G. Monitoring Report

When the on-site monitoring review has been completed and the work papers have been fully

    prepared, a report must be written reflecting the purpose and scope of the review. The report

    should clearly identify all findings and required corrective action including any necessary

    adjustments to the related financial reports. Written monitoring reports should be structured to

    assist the subrecipient in reaching their goals by providing feedback to them regarding program,

    financial, compliance and performance issues.

The findings to be identified in the written monitoring report should reflect a concise statement

    of fact and include the following information:

    ? Background information

    ? Problem analysis

    ? Outline of what was reviewed

    ? Size of the sample taken (if appropriate)

    ? Conclusions reached

    ? Recommendations for corrective action including timeframes

Preparation of the report and supervisory review should ideally be done within 10 days of the

    exit meeting. The report should be issued to the subrecipient’s Executive Director within 30

    days of the review's start date. If reasons exist such that the report cannot be issued within this

    timeframe, the work papers should detail these reasons. The WIB Director and CLEO should be

    copied on any monitoring report issued to a subrecipient. Additionally, NYSDOL must be

    notified of any significant findings resulting from the reviews.

For this purpose, significant findings are defined as those findings that: may have a material

    impact on the financial reports which the LWIA submits to NYSDOL; may materially impact the

    ability of the LWIA to meet established program performance measures; or represent a

    substantial violation of WIA statutory and regulatory requirements.

    H. Sanctions

The Monitoring agency should consider imposing sanctions against a subrecipient should the

    subrecipient agency willfully and flagrantly fail to take timely and responsive corrective action

    in response to significant issues identified in the monitoring report.

The specific sanctions that can be imposed should relate to the specific violations and/or to the

    scope of violations. Sanctions include the following items:

    ? Suspension of the affected program until corrective action is implemented

    ? Increased documentation requirements and/or increased monitoring frequency and/or

    scope

    ? Disallowance of costs associated with the particular violation or deficiency and seek

    repayment

    ? Denial or adjustment of requests for WIA funds until the violation or deficiency has been

    corrected

    ? Reallocation of unexpended or unobligated funds

    ? Contract cancellation.

     Preface 6

Acronyms

    AER Accrued Expenditure Report

CAP Cost Allocation Plan

    CLEO Chief Local Elected Official

    CFR Code of Federal Regulations

COW Cash Order Worksheet

CT Customized Training

DOL Department of Labor

    DSS Department of Social Services

DW Dislocated Worker

FIFO First In First Out

FOTA Financial Oversight and Technical Assistance Unit

    IEP Individual Employment Plan

IFB Invitation for Bid

    ISS Individual Service Strategy

    ITA Individual Training Account

LA Layoff Aversion

    LWIA Local Workforce Investment Area

    LWIB Local Workforce Investment Board

    MIS Management Information System

    MSCR Monthly Summary Cash Report

MSDCT Monthly Summary of Daily Cash Transactions

    NOA Notice of Obligational Authority

NPS Non Personnel Services

    NYSDOL New York State Department of Labor

OJT On-the-Job Training

    OMB Office of Management and Budget

OSOS One Stop Operating System Preface 7

RFP Request for Proposal

RRBR Rapid Response Business Retention PY Program Year

    SW Statewide Funds

TA Technical Advisory

TAA Trade Adjustment Act

TAG Technical Assistance Guide

    TEGL Training & Employment Guidance Letter

TRA Trade Readjustment Act

    WDT Workforce Development and Training Division

WIA Workforce Investment Act

    WIASARD Workforce Investment Act Reporting Data Format

WIB Workforce Investment Board

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