HomeMy WebLinkAbout20130439.tiffJOHN HICKENLOOPER
Governor
ELLEN GOLOMBEK
Executive Director
WILLIAM B. DOWLING
Director
ELISE LOWE-VAUGHN
Acting Director Workforce Programs
DEPARTMENT OF LABOR AND EMPLOYMENT
DIVISION OF EMPLOYMENT AND TRAINING
633 17th Street, 71h Floor
Denver, Colorado 80202-3627
January 29, 2013
William F. Garcia, Weld County Commissioner
PO Box 758
Greeley, CO 80632
Dear Mr. Garcia:
The Colorado Department of Labor and Employment, Workforce Development
Programs (WDP) conducted the annual on -site compliance review of the Employment
Services of Weld County (ESWC) from August 27 to August 30, 2012. The review
encompassed Workforce Investment Act (WIA) programs, Wagner-Peyser, Employment
Support Fund, Trade Adjustment Assistance Act Program (TAA) and discretionary
grants for the period July 1, 2011 through June 30, 2012. The review was performed in
accordance with CDLE Policy Guidance Letter # 08-18-WIA.
The executive summary and final report are enclosed. ESWC's responses have been
incorporated into the final report and a copy will be forwarded to the Chair of the Weld
County Workforce Investment Board (Dr. Mary Freitag) and the Chair of Weld County
Commissioners (William F. Garcia).
We would like to thank the staff of the Weld Workforce Region for the assistance they
provided to the State Workforce Monitors during all phases of the review. The staff was
courteous and their professionalism during the review was notable.
If you have any questions, please contact your Program Monitor, Petra Chavez at
303.318.8818 or petra.chaverstate.co.us.
Sincerely,
Elise Lowe -Vaughn, Acting Director
Workforce Development Programs
Cc: Celia Hardin, Supervisor, Workforce Development Programs
Keith McNeal, CDLE Auditor
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2013-0439
Program Year 2011
Annual Compliance Monitoring Report
Period of Review
July 1, 2011 through June 30, 2012
Workforce Investment Act
Wagner-Peyser
Special Initiatives, Discretionary Grants
And
Trade Adjustment Assistance Act
Final Report
For
Employment Services of Weld County
(ESWC)
January 2013
Prepared by Petra Chavez
Workforce Program Monitor
Colorado Department of Labor and Employment
Table of Contents
I. Executive Summary
II. Introduction and Methodology
A. Case file reviews
B. Risk assessment
Ill. Resolution of Previous Year Compliance Findings
A. Compliance findings
B. Risk assessment
IV. PY11 Monitoring Results
A. Definitions
B. Compliance findings and Action items
C. Recommendations
D. Technical assistance and training
V. Recognition
A. Best Practices
B. Acknowledgements
VI. Attachments
A. File review chart
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Colorado Department of Labor and Employment
Workforce Development Programs
I. EXECUTIVE SUMMARY
From August 27, 2012 to August 30, 2012 the Colorado Department of Labor and Employment
(CDLE) conducted an annual compliance review of the Employment Services of Weld County
(ESWC). Program monitors reviewed the areas of governance, administration, program and
service delivery systems as they relate to the Workforce Investment Act (WIA) Title I and
Wagner-Peyser (WP) Act, as well the Trade Adjustment Assistance Act (TAA) program.
Best Practices, acknowledgements, and action items found in the review are summarized
below.
Best Practices:
• Employment Services of Weld County has been noted for excellence in program
performance for the State Energy Sector Partnership (SESP) Initiative. The region
surpassed the target number of participants and expended all grant funds; successfully
meeting and/or exceeding performance measures.
• On -the -Job National Emergency Grant (OJT NEG): Employment Services of Weld
County is recognized as the first region in the State of Colorado to achieve participant
performance measures and to fully expend all grant funding. Collaboration between the
OJT NEG and Career Ready Certificate is a noted example of excellence in leveraging
resources.
• Employment Services of Weld County is recognized for its successful development of its
youth programs; The Weld County Youth Conservation Corps (WCYCC), Teamwork,
Innovation, Growth, Hope, Training (TIGHT) and AmeriCorps.
• The focus of the Sectors initiative in Weld is to focus on the Business needs; and in turn
sustaining businesses and creating future job opportunities. The Sectors initiative was
implemented in Weld to serve the community by encouraging sustainable manufacturing
through training to reduce waste. This program increased cross -agency collaboration
between Workforce, Economic Development, and Education with a focus on the
employer, and in suit, to the employee.
Acknowledgements:
• Career Ready Certificate (CRC) is successfully leveraged with other programs.
Employment Services of Weld County has served over 1000 clients and issued 861
certificates in Program Year 2011 (PY11).
Action Items:
Action item #1 was originally identified as a compliance finding but after further review it is clear
that the incident is an exception and does not represent a pattern.
Action Item #1: A $25.00 incentive payment was awarded to a participant who did not appear to
meet the requirements outlined in local policy: Work Experience Placements including
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Background Checks and Youth Incentive Policy; "for the purposes of incentives, youth must
demonstrate gains by moving up one full level". The youth participant did not achieve a full
level Literacy Numeracy (LN) gain (8.2-8.5); therefore, this finding results in a $25.00
questioned cost.
Action Item #2: SECTORS participants were not entered into Connecting Colorado/Job Link.
As a result of this action item, 47 SECTOR participants will be entered into Connecting
Colorado. Program Guidance Letter (PGL) #10-02-WIA Colorado SECTORS Implementation
Grants: Reporting and Evaluation states, "All grant participants are enrolled in Job Link using
the grant's program code and a case file is established for each participant" (p.3).
��. INTRODUCTION AND METHODOLOGY
Introduction
From August 27, 2012 to August 30, 2012, the State Workforce Program Monitors with the
Colorado Department of Labor and Employment (CDLE) conducted an onsite compliance
monitoring review of the workforce programs operated by Weld for the program year 2011
(PY11), encompassing the date range of July 1, 2011 to June 30, 2012. This comprehensive
review included the following programs: WIA Adult, Dislocated Worker, and Youth programs,
Wagner-Peyser (WP), Special Projects/Grants and the TAA Program. This review was
conducted in accordance with CDLE Policy Guidance Letter (PGL) #08-18-WIA which includes
as attachments all the monitoring instruments to be used throughout the review.
Prior to onsite monitoring, an entrance interview was conducted on August 27, 2012 with the
management team from ESWC, including: Linda Perez, Ted Long, Tami Grant, Marie Llamas,
Ann Stelling-Bruce and Dora Lara, and CDLE personnel: Petra Chavez, Celia Hardin, Candy
Frank, Rob Hanni, Joy Major and Terri Bohannon.
An exit interview detailing the findings of compliance monitoring was conducted on
September 13, 2012 with the management team from ESWC, including: Linda Perez, Ted Long,
Tami Grant and Marie Llamas, and CDLE personnel: Petra Chavez, Celia Hardin and Rob
Hanni.
Annual compliance monitoring is administered with a view towards assessing risk in key
categories in order to systematically identify areas of success, as well as those in need of
improvement. Monitoring and risk assessment can identify deficiencies and trends and may
result in targeted training and technical assistance.
Methodology
A. Case File Reviews
A random case file sample is generated at CDLE for each of the programs operated in the
region. This file sample was sent to the region eleven calendar days before the beginning of
the monitoring.
WIA Programs:
• Dislocated Worker: A random sample of 19 cases;
• Adult: A random sample of 22 cases; and
• Youth: A random sample of 19 cases.
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Wagner-Peyser Program:
• Wagner-Peyser Participant Files: A random sample of 29 files; and
• Wagner-Peyser Job Orders: A random sample of 25 files.
Special Initiatives:
• Trade Adjustment Assistance: A random sample of 20 files;
• Veterans Workforce Investment Program: A random sample of 6 files;
• Career Ready Colorado (CRC): A random sample of 5 files;
• Emergency Unemployment Compensation (EUC): A random sample of 6 files;
• On -the -Job National Emergency Grant (OJT NEG): A random sample of 5 files;
• State Energy Sector Partnership (SESP): A random sample of 10 files; and
• Strategies to Enhance Colorado's Talent through Regional Solutions (SECTORS): A
random sample of 10 files.
B. Risk Assessment
Annual compliance monitoring is conducted with a view towards assessing risk in four key
categories: 1) Governance; 2) Administration, Program and Financial Systems; 3) Program
Services, Delivery and Documentation; and 4) Performance Accountability. CDLE's
monitoring approach is outlined in detail in PGL #08-18-WIA, and identifies two
categorizations of risk, low and high. A rating of low risk generally indicates first time areas
of concern or warning. A rating of high risk indicates larger systemic gaps, repeat areas of
concern or warning, and a discernable pattern of shortcomings in one or more areas.
Because the overarching categories encompass many parts, sub -categories were utilized to
provide a targeted analysis, and clearer identification of risk. Categories where the region is
found to be performing well and in compliance with Federal, State and local requirements
are deemed to be no -risk.
III. RESOLUTION OF PREVIOUS YEAR COMPLIANCE FINDINGS AND RISK
ASSESSMENT
A. Program Year 2010 (PY10) Compliance Findings
There were no compliance findings identified during the PY10 review.
B. Risk Assessment
Last year the monitor assessed that ESWC was at limited to no risk in the implementation of
Workforce Investment Act and Wagner-Peyser Programs.
The monitor also found ESWC to be Low/No Risk in the implementation of Workforce
Investment Act and Wagner-Peyser Programs during PY11. CDLE recognizes the efforts
being made by ESWC to continuously improve and maintain its highest standards as it
implements its WIA and WP programs.
IV. PY11 MONITORING RESULTS
A. Definition of Compliance Finding, Action Item, and Recommendation:
• A compliance finding is a violation against legal or policy requirements considered to be
a more prevalent problem than an individual exception to the rule. Compliance issues
must be corrected (if possible) to avoid any potential repercussions or corrective actions.
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• An action item is a specific request to make a correction to avoid the possibly of it
becoming a compliance finding in the future.
• A recommendation addresses an issue where there is currently no compliance finding,
but a recommendation is made to improve or enhance a program or system's processes
or outcomes. A workforce region is not required to implement recommendations made
in the report.
B. Compliance Findings and Action Items
Governance: No compliance issues or actions items identified.
Administration: No compliance issues or actions items identified.
WIA Dislocated Worker Program: No compliance issues or actions items identified.
Wagner-Peyserl Business and Job Seeker: No compliance issues or actions items
identified.
WIA Youth Program: Review identified 1 action item.
Action Item #1: A $25.00 incentive was awarded to a participant who did not appear to meet
the requirements outlined in local policy: Work Experience Placements including
Background Checks and Youth Incentive Policy; "for the purposes of incentives, youth must
demonstrate gains by moving up one full level". The youth participant did not achieve a full
level Literacy Numeracy (LN) gain (8.2-8.5). $25 questioned cost.
Employment Services of Weld County Response: Although we agree the incentive may
have not met the strict interpretation of our policy for attaining a full level literacy/Numeracy
gain, Employment Services contends this should not be a compliance issue based upon the
definition identified within CDLE's report.
That definition states: "A compliance finding is a violation against legal or policy
requirements considered to be a more prevalent problem than an individual exception to the
rule". There were 19 youth files reviewed under the PY 11 monitoring as well as numerous
files reviewed under previous monitoring visits. This was the first time this exception was
noted and therefore we would argue this incident would best be classified as an action item
rather than a compliance issue. The Weld County Youth Council has subsequently
reviewed the policy and has modified our local policy to include the recommendations made
by CDLE during the monitoring visit.
CDLE Response: Response accepted. CDLE understands that the incident is not
indicative of a pattern or area of concern but CDLE will continue to monitor during annual
reviews to insure compliance.
Special Initiatives: The SECTORS participant files were not available for review during the
onsite review as they were not entered into Connecting Colorado and files were not
available. Weld County confirmed that they completed applications for each participant and
a random sample of 10 files was reviewed on September 27, 2012.
Action Item #2: Preliminary discussions have resulted in a consensus that the original
number of SECTOR participants sited in the Expenditure Authorization will be entered into
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Connecting Colorado. PGL #10-02-WIA Colorado SECTORS Implementation Grants:
Reporting and Evaluation states, "All grant participants are enrolled in Job Link using the
grant's program code and a case file is established for each participant" (p.3). CDLE
requests that ESWC enter 47 participant records into Connecting Colorado based on the
executed Expenditure Authorization (EA) for the grant; ESWC is in agreement.
Employment Services of Weld County Response: As was discussed with CDLE
monitors and Sector Project staff on numerous occasions, it was Employment Services of
Weld County's understanding, and interpretation of the cited PGL, that since we did not
provide any services to any unemployed workers (which would have met the common
definition of a client) and were only providing sector services to manufacturing employers to
meet the training needs of their incumbent workforce, the language in PGL 10-02-WIA
concerning entering data on clients was not applicable. If we would have served any
unemployed individuals under the initiative we certainly would have created a client file and
subsequently entered information into Connecting Colorado as specified in the PGL.
To facilitate tracking services provided under the Sector initiative, Employment Services and
CDLE came to an agreement to enter data as specified. Employment Services will still not
be able to create a "client file" per se, since under the structure of this initiative we did not
have any direct contact with incumbent workers served and the extent of documentation will
be limited to our locally developed Sector application which provides limited information to
allow for a partial registration, and an Immigration Affidavit. No additional information was
collected.
As of this response, Employment Services has entered the requisite SE -08 programs code
and an associated IW service on all of the individuals served to date under this initiative.
We are still in the process of pulling data together as directed by CDLE to transmit
information to CDLE MIS staff to enter the correct date of service since records are locked
for any date prior to July 1, 2012. We anticipate this will be completed within the next
couple of weeks.
CDLE Response: CDLE accepts ESWC's response and will assist in entering the correct
dates of services for participant records in ConnectingColorado.
Performance Accountability: Performance measures and expenditure levels for PY11 are
all within acceptable parameters.
C. Recommendations
Governance:
Recommendation A: Currently ESWC does not have a Memorandum of Understanding
(MOU) for the Older Worker Americans Act. PGL 08-18-WIA stipulates that as a One -stop
partner, an MOU is needed for Title V Older Americans Act (Senior Community Service).
Based on discussion with ESWC staff, ESWC has submitted a petition to fulfill this
requirement and status is pending. It is recommended that ESWC notify their region monitor
once this MOU is established.
ESWC Response: Employment Services agrees with this recommendation and will
continue to attempt to identify and connect with the appropriate entity to develop and MOU
and agrees to notify the monitor once an MOU is established.
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CDLE Response: Response accepted.
Administration: No recommendations.
WIA Dislocated Worker/Adult/Youth:
Recommendation A: The Dislocated Worker review found 3 files that lacked case notes for
services documented in Connecting Colorado. The dates of service occurred prior to the
12-06-WIA; Guidance on Data Integrity and the customer Participation Cycle for WIA and
TAA Programs policy.
It is recommended that ESWC continue to utilize their internal monitoring/review process to
insure that all future participants have documented case notes for each service in
Connecting Colorado.
ESWC Response: Employment Services developed its Data Integrity and Customer
Participation Policy in accordance with CDLE policy guidance which was issued on June 6,
2012. The discrepancies noted in this recommendation will not be an issue in the future as
case notes in Connecting Colorado are now required for certain activities.
CDLE Response: Response accepted.
Recommendation B: The WIA Adult review also presented an issue where a hard exit is
evident (participant was exited from the program without a service). Participant file lacked a
case note for exit service dated 04/19/12. The date of service is prior to PGL 12-06-WIA;
Guidance on Data Integrity and the Customer Participation Cycle for WIA and TAA
Programs. It is recommended that ESWC continue to utilize internal
monitoring/review/training processes to ensure future participant files are in compliance with
PGL 12-06-WIA.
ESWC Response: Employment Services agrees with this recommendation and will
continue to monitor these areas as part of the Data Integrity Policy implementation in June
2012.
CDLE Response: Response accepted.
Recommendation C: Youth: If a participant pre-tests above grade 9 level in Literacy
Numeracy (LN), a post-test is not required. If a post-test is not administered, it is
recommended that the field be left blank to indicate such.
First WIA Youth funded service should be performed on the registration date and should be
documented, at a minimum, by case notes.
ESWC Response: Employment Services agrees with this recommendation and will
continue to monitor these areas.
CDLE Response: Response accepted.
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Wagner-Peyser/Business and Job Seeker Services:
Recommendation D: Two participant registrations were incomplete. CDLE recognizes that
it can be difficult to monitor all registrations entered into Connecting Colorado but it is
recommended that internal reviews continue as a means to identify and rectify as many
incomplete registrations as possible.
ESWC Response: Employment Services agrees to continue to monitor these areas.
CDLE Response: Response accepted.
Trade Adjustment Assistance:
Recommendation E: Incorrect service codes entered into Connecting Colorado may result
in inaccurate outcome measures and exit dates. It is recommended that policy WIA/TAA
Data Integrity and Customer Participation Cycle Policy is reviewed for clarity and that case
managers receive additional training and/or guidance on this topic.
ESWC Response: Employment Services developed its Data Integrity and Customer
Participation Policy in accordance with CDLE policy guidance which was issued on June 6,
2012. The discrepancies noted in this recommendation are unclear as this was not
discussed with staff, however CDLE staff was invited to provide training to Employment
Services case managers and this training has taken place. We will continue to monitor
activities to ensure they are accurate and in accordance with policy.
CDLE Response: Response accepted.
Recommendation F: If a participant withdraws from training then training plans must be
amended or rescinded and a waiver revocation must be issued accordingly. CDLE
recommends that ESWC review the WIA/TAA Data Integrity and Customer Participation
Cycle Policy.
ESWC Response: Employment Services agrees with this recommendation and will submit
information to CDLE staff and also will continue to ensure revocations are issued by CDLE
TAA staff as appropriate.
CDLE Response: Response accepted.
D. Technical Assistance/Training for ESWC
CDLE/WDP Monitor Team staff agreed to conduct case management training for Weld WIA
staff, to include the following topic areas: WIA Data Validation, exit date reporting, reporting
of follow-up activity, and general compliance issue avoidance. The training occurred on
September 26, 2012. Weld County is to be commended for taking proactive steps to ensure
compliance with federal and state mandates.
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V. RECOGNITION
A. Best Practices
• Employment Services of Weld County has been noted for excellence in program
performance for the SESP Initiative. The region surpassed the target number of
participants and expended all grant funds; successfully meeting and/or exceeding
performance measures.
• Employment Services of Weld County is recognized as the first region in the State of
Colorado to achieve participant performance measures and to fully expend all grant
funding. Collaboration between the OJT NEG and Career Ready Certificate is a
noted example of excellence in leveraging resources. Ongoing internal quality
control/internal monitoring are in place and case file notes were very comprehensive.
• Employment Services of Weld County is recognized for its successful development
of its youth programs; The Weld County Youth Conservation Corps (WCYCC),
Teamwork, Innovation, Growth, Hope, Training) TIGHT and AmeriCorps.
- The WCYCC program initially worked with at -risk youth but has evolved to
educate and challenge all young adults from ages 11-24. Participating youth are
exposed gain leadership and peer accountability skills in addition to the hands on
experience behind the mechanics of land, water, and energy conservation.
- In 2004, WCYCC began operating the TIGHT (Teamwork, Innovation, Growth,
Hope, Training) program. As a partner with the Weld County Child Welfare
Division, WCYCC's TIGHT crew consists of corps members ages 14-17, who are
referred to the program by case managers. TIGHT specifically serves at-
risk/high-risk youth and is a last alternative to out of home placement or the
Department of Youth Corrections. TIGHT works closely with Child Welfare, Weld
County Probation, North Range Behavioral Health, and the 19'" Judicial District to
ensure that corps members are engaged in a positive and structured
environment where they can work on educational achievements and healthy
engagement in their communities.
The AmeriCorps program offers a team -based learning experience and
opportunities for developing job readiness skills such as communication,
leadership, and responsibility.
B. Acknowledgements
• The CRC is successfully leveraged with other workforce programs. Employment
Services of Weld County has served over 1000 clients and issued 861 certificates in
PY11.
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