HomeMy WebLinkAbout20120037.tiff JOHN HICKENLOOPER
Governor oe.cOL- DEPARTMENT OF LABOR AND EMPLOYMENT
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ELLEN GOLOMBEK in%(-_ o WELD COUNTY
Executive Director 633 17th Street,7th Floor
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RECEIVED
December 8, 2011
Barbara Kirkmeyer, Chair
Weld County Board of Commissioners
P.O. 758, 915 10th St.
Greeley, CO 80631
Dear Ms. Kirkmeyer:
Enclosed please find the PY10 Final Annual Compliance Monitoring Report prepared by
the Colorado Department of Labor and Employment (CDLE). We appreciate your
support of the mission and work of the Employment Services of Weld County (ESWC).
A copy of this final report is being sent to you as Chair of the Board of Weld County
Commissioners. Thank you, for your contribution to Colorado's Workforce system.
Sincerely,
v //
Elise Lowe-Vaughn, Acting Director
Workforce Development Programs
Cc: Linda Perez
Milt Wedgewood
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- 11-- 2012-0037
PY10 Annual Compliance Monitoring
Period of Review
July 1 , 2010 through June 30, 2011
Workforce Investment Act
Wagner-Peyser
Special Initiatives, Discretionary Grants
Veteran's Program and
Trade Adjustment Assistance Act
Final Report
For
Employment Services of Weld County
(ESWC)
December 2011
Prepared by Bill Volz
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
III. Resolution of Previous Year Compliance Findings
A. Compliance findings
B. Risk assessment
IV. PY10 Monitoring Results
A. Definitions
B. Compliance findings and Action items
C. Recommendations
D. Risk Assessment
E. Technical assistance and training
F. Feedback or input from the region
V. Recognition
A. Acknowledgements
B. Best Practices
VI. Attachments
A. File review chart
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Colorado Department of Labor and Employment
Workforce Development Programs
I. EXECUTIVE SUMMARY
From July 18, 2011 to July 29, 2011, 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 Act, as well as their American Recovery and Reinvestment Act (ARRA)
counterparts. During this review it is important to note that monitors also reviewed the Trade
Adjustment Assistance Act (TAA) program in ESWC.
Best Practices, acknowledgements, compliance findings and action items found in the review
are summarized below.
Best Practices:
• The State Coordinator of the On-the-Job Training National Emergency Grant (OJT NEG)
Grant recommends that ESWC could be a mentor region by providing national guidance
on its effective program execution, file maintenance, business outreach, participant
recruitment and training plan development.
• ESWCs TAA Specialists' development of both a PowerPoint presentation and the use of
specifically designed forms to help guide and ensure the understanding of the TM
program's many complexities to Weld County's TAA entitled participants.
• The Individual Service Strategy (ISS) form used by ESWC Youth WIA is one of the best
in the state. It is comprehensive in its coverage of all the required elements of a good
case plan.
Acknowledgements:
• Acknowledgement: CDLE recognizes ESWC for its collaborative Outlook Calendar
which tracks individuals and lab testing from start to finish.
• Acknowledgement: Each ESWC On-the-Job Training National Emergency Grant (OJT
NEG) clients' supportive services are leveraged to the Colorado Ready Certificate.
• Acknowledgement: CDLE recognizes Weld's new Business Training Manual. This
manual is seen as a model for other regions in the state. It provides internal
consistencies for Business Service operations and ensures that with absent staff daily
activities will continue with maximal productivity and customer service.
Compliance Findings: None were identified during this review.
Action Items:
Action Item #1: Two policies were identified as missing elements as described in the most
current Program Guidance Letter (PGL) issued by CDLE. CDLE requests that each PGL and
local policy are reviewed to verify that the local policy contains the required information.
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Action Item #2: Per the stringent tests of data validation, start and end dates of Occupational
Skills Training (OCs) must match the actual start and end dates of the training.
Action Item #3: The training (TR) service should be entered (and closed) on the day that the
vouchers are given to the client. Case managers must enter a TR service every time a voucher
is written and given to the client. A case manager can obligate some TR assistance up front
and put that on the Individual Employment Plan (IEP), but a service is required each time TR
assistance is actually provided. The date as recorded as TR in Connecting Colorado must
match the case note and voucher.
* Details on individual cases can be found in the attachments to this report.
II. INTRODUCTION AND METHODOLOGY
Introduction
From July 18, 2011 to July 29, 2011, 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 2010 (PY10),
encompassing the date range of July 1, 2010 to June 30, 2011. This comprehensive review
included the following programs: Workforce Investment Act (WIA) Adult, Dislocated Worker,
and Youth programs, Wagner-Peyser (WP), Veteran's, Special Projects/Grants, ARRA 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 July 18, 2011 with the
management team from ESWC, including: Ted Long, Tami Grant, Marie Llamas, Kris Armstrong
and Dora Lara and CDLE personnel: Bill Volz, Celia Hardin, Mona Barnes, Art Ruiz, Joy Major,
Wendy Corley and Don Schofield.
An exit interview detailing the findings of compliance monitoring was conducted on
August 15, 2011 with the management team from ESWC, including: Linda Perez, Ted Long,
Tami Grant, Marie Llamas, Kris Armstrong and Dora Lara and CDLE personnel Bill Volz, Celia
Hardin, Mona Barnes, Art Ruiz, Joy Major, Wendy Corley and Don Schofield.
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 seven calendar days before the beginning of
the monitoring.
WIA Programs:
• Dislocated Worker and American Recovery and Reinvestment Act (ARRA)
Dislocated Worker: A random sample of 18 cases;
• Adult and ARRA Adult: A random sample of 20 cases; and
• Youth and ARRA Youth: A random sample of 22 cases.
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Wagner-Peyser Program:
• Wagner-Peyser Participant Files: A random sample of 10 files; and
• Wagner-Peyser Job Orders: A random sample of 10 files.
Special Initiatives:
• Online Learning Grant: A random sample of 9 files;
• Veterans Workforce Investment Program: A random sample of 6 files;
• Career Ready Colorado (CRC): A random sample of 8 files;
• Microsoft Elevate America: A random sample of 8 files;
• OJT - National Emergency Grant (NEG): A random sample of 5 files;
• State Energy Sector Partnership (SESP): A random sample of 5 files; and
• Re-Employment Stimulus Grant (RES): A random sample of 8 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 2009 (PY09) Compliance Findings
CDLE identified one compliance issue in PY09:
ESWC failed to meet the 70% expenditure goal for PY09 WIA Adult, Dislocated
Worker and Youth funds. They were found to be out of compliance with State
policy on this issue.
Weld satisfactorily responded and corrected this compliance finding by spending down its
funds in PY10. CDLE changed its compliance finding to a recommendation.
Weld disagrees with the statement that there was a Compliance Finding during PY 09.
Although CDLE's initial report indicated this as an issue, after Weld County submitted
its comments and rebutted this area, it was our understanding CDLE determined it to
NOT be a compliance issue.
CDLE Response: ESWC's response is accepted. The findings and responses above
are the records of what transpired in the PY09 report. This compliance finding was
changed to a recommendation though left under the compliance header.
B. Risk Assessment
Last year the monitor assessed that ESWC was at limited to no risk in the implementation of
Workforce Investment Act or Wagner-Peyser Programs.
CDLE appreciates the efforts being made by ESWC to improve and maintain its highest
standards as it implemented its PY10 WIA and WP Programs.
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IV. PY10 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.
• 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
Action Item #1: Two policies were identified as missing elements described in the State
PGL. CDLE requests that each PGL and local policy are reviewed to verify that the local
policy contains the following information:
a.) Action Required: WIA Work Experience Opportunities and Youth Common Measures
(PGL# 10-03 WIA). ESWCs local policy needs to indicate how much time is anticipated
for each training objective within an individual work experience opportunity, and how
goals and progress will be measured so expectations are clear for all parties to follow.
Region Response: Weld will review the policy and ensure the above cited elements
are identified within our WIA Work Experience policy and include the identified
information in a revised policy.
CDLE Response: ESWC's response is accepted. Please implement by January 30, '12.
b.) Action Required: Adult Priority of Service (PGL # 00-12 WIA1) — Please
add/strengthen language on how ESWC Workforce Investment Board (WIB) will
determine when to invoke this policy and what is the process or procedure to invoke it.
Region Response: Weld agrees to review the Priority of Services policy and as
necessary, strengthen the language regarding how the Workforce Board will
determine when to invoke the policy and to identify the process for invoking the
Priority of Service.
CDLE Response: ESWC's response is accepted. As necessary, please complete the
reviewing and changes to the Priority of Services by January 30, 2012.
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WIA Dislocated Worker Program
Action Item #2: Per the stringent tests of data validation, start and end
dates of all OCs (Occupational Skills service in Connecting Colorado) must
match the actual start and end dates of the training.
Action Required: Please correct the dates in the files indicated. Please ensure that all
OC start and end dates are correct as of 7-1-11.
Region Response: Weld agrees to review the OC activities in the files indicated and
will make corrections as needed. However Weld will be unable to meet the suspense
date identified as this appears to be a typo since the monitoring dates were after the
suspense date given.
CDLE Response: ESWC's response is accepted.
Action Item #3: The transportation (TR) service should be entered (and closed) on the
day that the vouchers are given to the client. Weld must enter a TR service every time a
voucher is written and given to the client. The case manager can obligate TR assistance
up front and put that on the IEP, but a service is required each time TR assistance is
actually provided. The date in Connecting Colorado for TR must match the case note
and voucher.
Action Required: Please correct this process on all transportation services provided
after 07-01-11.
Region Response: Partially agree. Prior to changes within Connecting Colorado/Job
Link the policy, as well as guidance from previous CDLE programs monitors, was to
have one activity for Transportation Assistance (TR) supportive services and update
the amount of assistance provided within that one activity. This process was agreed
upon to avoid the potential of having vast numbers of TR services cluttering the client
record. In July 2011, CDLE revised Connecting Colorado/Job Link and made certain
services mandatory one day services. The TR service is one of those services that
automatically close the same day as they are entered; therefore this Action Item
becomes moot.
CDLE Response: ESWC's response is accepted.
* Details on individual cases can be found in the attachments to this report.
Wagner-Pevser/ Business and Job Seeker: No Compliance Issues
WIA Youth Program: No Compliance issues
Special Initiatives: No Compliance issues
Performance Accountability
Performance measures and expenditure levels will be assessed for compliance at the end of
the program year, and the regions will be notified at that time.
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C. Recommendations
Administration:
Recommendation A:
When writing local policies, CDLE encourages local regions to provide meaningful guidance
and processes with local policies that not only meet the requirements of WIA, but also help
establish the foundation and set standards that lead to improved case management, follow
up services, and quality customer service. The policy can be presented as a training guide
for case managers and other staff that might need to review information on the subject and
should include local implementation guidelines for WIA eligibility and Veterans' Priority of
Service.
WIA Dislocated Worker/Adult/Youth:
Recommendation 8:
It is recommended that ESWC clarify in the supportive service policy what is covered (and
exempted) under "job related medical expenses" which has a cap of$100.
Recommendation C:
It is recommended that ESWC implement a process that will determine and document the
amount of transportation assistance needed, such as a mileage calculation sheet, that
documents the number of miles between the participant's home and his/her training and
what kind of mileage their automobile gets. ESWC has provided large amounts of
transportation assistance to individual clients (for example, $1600 and $2000). The need
for this level of assistance should be justified by documenting that they would not be able to
participate in the program without the assistance.
Wagner-Peyser/Business and Job Seeker Services:
Recommendation D:
Align the Disabled Veterans Outreach Program (DVOP) coordinator with the Weld WIA
Team and encourage the DVOP to attend Technical Assistance on Data Validation and
Integrity to ensure the enhancement of intensive services for all veterans is implemented
appropriately.
Weld County agrees to review each of the recommendation areas listed above and, as
appropriate and if we determine the suggestions are ones that will truly benefit our
programs and procedures to make changes or improvements as needed. Weld is
committed to quality improvement and is always open to enhancing what we feel are
already quality processes.
CDLE Response: ESWC's response is accepted.
D. Risk Assessment: All areas are considered at Low/No Risk for PY10
E. Technical Assistance/Training for ESWC
• Employment Services of Weld County has asked for clarification on whether they can
delete a Veteran's WIA application once the participant decides not to participate in WIA.
Response: Regions should not delete any Veteran applicants or registrants from
Connecting Colorado (or Job Link) as this will compromise the integrity of the data. In
response, CDLE encourages regions to document when a participant declines an
enrollment in WIA services on the Veteran's case notes. In addition, the region may
want to maintain a log of all Veteran applicants that have declined WIA services so that
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ESWC may respond to any impacts this may have on the overall percentage of Veteran
vs. Non-Veteran applicants to registrants.
• The ESWC Veterans DVOP has requested more understanding and cross training with
Weld staff in WIA.
CDLE Response: Recommendation D above has been provided to Weld to develop
consistent cross training between DVOP and WIA staff.
F. Feedback and/or Input from ESWC
• Weld reflected that the Microsoft "Elevate America" project involved significant staff time
and no funds were available to help cover those costs. Additionally, similar tutorial
Microsoft training was/is available online to customers at no cost and does not require
vouchers from Microsoft. ESWC recommends that CDLE might review projects closer as
to their implementation effect in the field.
• Regarding the Online Learning Grant: Weld suggested that it was challenging tying the
training to a career. Weld further stated that this program was "loose in expectations
and requirements." "Goals needed to be better established at CDLE's end and for the
participants receiving the grant's support."
V. RECOGNITION
A. Acknowledgements
• Recognition: CDLE commends ESWC's leveraging its OJT NEG clients' supportive
services with the Colorado Ready Certificate program.
• CDLE recognizes ESWC for the collaborative Outlook Calendar that tracks
individuals and lab testing from start to finish; it provides all case managers access
to direct scheduling; and draws statistical data of clients. In addition, it saves money
by eliminating the position for an administrator to manage this process -while
serving two locations (Ft. Lupton and Greeley). This system affords the county the
ability to service more clients, more readily and more efficiently
• Acknowledgments for the TAA Specialists' development of both a PowerPoint
presentation and the use of specifically designed forms to help guide and ensure the
understanding of the TAA program's many complexities to Weld County's TAA
entitled participants.
• Recognition to ESWC's Wagner-Peyser Job Seeker Team for its Workforce
Reception, Resource Room and Workshops. Outreach includes but is not limited to:
the East African Committee (Somalia and Burmese) for ESL and GED; Aims
Community College; Rite to Read; local libraries. ESWC runs a series of monthly
reports which provides them with information for internal monitoring and status
review. Weld's Job Seeker Team developed a class on Transferable Skills for the
RES client—this class provides information to expand the job seeker's job search
with current skills.
• Weld is recognized for developing a Business Training Manual. The monitor was
provided a draft of this manual. This manual is seen as a model and method of
cross training to preclude the high risk that only one staff member can perform the
duties of the business services unit at ESWC. The manual also ensures
standardization of procedures working with businesses, taking and maintenance of
job orders.
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B. Best Practices
• The State Coordinator of the OJT NEG Grant recommends that ESWC could be a
mentor region by providing national guidance on its effective program execution, file
maintenance, business outreach, participant recruitment and training plan
development.
• Clearly a best practice is Weld's development of a "TAA PROGRAM DASHBOARD"
form; it should be shared with all TAA case managers statewide. The form attached
to the inside cover of each case file includes all critical information and provides both
the case manager and any reviewer a true snapshot of the required documentation
collected for each participant. The TAA case manager is able to align the training
program and training placement outcomes with the local areas training providers and
educational institutions curriculum, financial aid and accounts payable departments.
• ESWCs main case manager for TM has gone far beyond assisting workers in the
filing of their TAA Petitions. This staff member is able to assist those potential trade
affected workers that have absolutely no knowledge of the TM program and the
benefits that they may be entitled to. Direct knowledge of the program and local area
employers allows the case manager to determine whether customers may be
considered as trade affected workers. This staff person is a strong advocate for
those that may qualify for their entitlement and has learned to ask the right questions
to submit accurate and complete documentation, thus successfully having all of the
petitions filed approved and several deemed eligible and entitled to the benefits of
the TM program.
• The Individual Service Strategy (ISS) form used by ESWC's Youth Programs is one
of the best in the state. It is comprehensive in its coverage of all the required
elements of a good case plan. It's also structured to allow for changes and updates.
The monitor would offer it to other workforce regions as an example of a quality ISS
template.
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