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STATE OF COLORADO
GOVERNOR'S JOB TRAINING OFFICE ecow
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720 South Colorado Blvd.,Suite 550
Denver,( 80222 �. .
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Phone(1031 758-5020 'a'6
FAX(30 ti 758-5578 Roy Romer
Governor
Leslie S.Franklin
Director
July 27, 1994
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Ms . Constance Harbert C, ,,)
County Commissioner T'H T1 '
P .O. Box 758
Greeley, Colorado 80632
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Dear Commissioner Harbert :
Attached is the final monitoring report of the Program Year 1993
(PY 93) Compliance Review of the Weld County Department of Human
Resources . The review indicates that the SDA is in compliance with
the amended JTPA.
This review was conducted during January, 1994 , by the Governor' s
Job Training Office, in compliance with the Amended Job Training
Partnership Act (JTPA) , Section 164 .
The Weld County Department of Human Resources staff is to be
commended for the quality of their efforts in implementing the
many changes imposed by the amended JTPA, and their on-going
programma icfine tuning.
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Attachment
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1992 AMENDMENT IMPLEMENTATION
MONITORING REPORT
Service Delivery Area: Weld County Department of
Human Resources
Program: Title II-A/C Program Year 1993
Grant Award: Title II-A $ 322, 008
Title II-C , $ 225, 729
Period of Performance: July 1, 1993 - June 30, 1994
Monitoring Dates: January 5, 7, 11-14, 1994
Monitor(s) : Peggy Fussell MIS Coord.
Julia Henry St Monitor
Thirza Kennedy Purchasing Agent
Elise Lowe-Vaughn State Field Rep.
Don Mitchell EDWAA Specialist
Scott Toland Fiscal Monitor
SDA Staff: Linda Perez Director
Ted Long Special Programs
Coordinator
Marilyn Carlino Fiscal Officer
I. INTRODUCTION
A Program Year 1993 (PY 93) compliance review of Weld County
Department of Human Resources, Service Delivery Area' s (SDA' s)
Title II-A\C program was conducted at the administrative
office on January 5, 1994 . Representatives from the Governor' s
Job Training Office (GJTO) conducted the on-site review.
The review focused on the SDA' s implementation of the changes
initiated by the amended 1992 Job Training Partnership Act
(JTPA) . These changes in program policies were enacted at both
federal and state levels. The SDAs were required to
incorporate the required changes to existing policies and
establish new policies and/or agreements where specified.
In conjunction with this review, staff from the GJTO
provided on-site technical assistance when deficiencies were
noted.
The SDA Director, Ms . Linda Perez, assigned appropriate staff
to provide necessary information for this review.
The review covered the following general areas :
Section 1- Program Review
- PIC Certification
- Annual Reports
- Bonus and Incentives
- Policies
- Interview Questions
Section 2- Eligibility Determination and Management
Information Systems (MIS)
Section 3- Follow-up
Section 4- Technical Assistance
Section 5- Performance Standards
Section 6- Fiscal
Section 7- Procurement
Methodology included:
* Use of the GJTO Monitoring Guide;
* Review of Policies and Agreements;
* Discussion with appropriate staff; and a
* Review of client files
II. SUMMARY OF FINDINGS
For the past several years, Weld SDA has been fine tuning its
program to better serve the needs of the economically
disadvantaged and the community at large . A keystone in the
SDA' s shift in focus has been education. This program focus
lends itself to many of the changes initiated by the amended
1992 JTPA. The SDA is to be commended for its smooth
transition towards amendment implementation.
No compliance issues were noted during this review. However,
the SDA should note that recommendations cited in this report
are for the SDA' s benefit, and address full implementation of
the amendments .
III. PROGRAM REVIEW
A. Private Industry Council (PIC) Certification
The GJTO reviewed and certified the PIC as having met the
requirements for composition and appointments that are
consistent with Section 102 of the amended JTPA and PGL
93-17-AD2 .
B. PY 92 Title II-A and Il-B Annual Report
Annual reports for PY 92 Titles II-A and II-B were
submitted to the GJTO and were in accordance with the
guidelines specified in Section 104 .
Page 2 of 14
C. Policies
The monitor reviewed the following policies and
agreements for compliance with the amended 1992 JTPA,
JTPA Letters, and Policy Guidance Letters (PGL' s) .
The SDA is to be commended for the timely implementation
and comprehensive nature of its policies.
1. On-the-Job Training (OJT) In complying with
changes specified in the OJT PGL #93-26-P2, SDAs were to
add language to their existing policy to include: (1) the
wage for youth must equal ,or exceed the previous year' s
average placement wage for adults; (2) the maximum hours
or duration of an OJT; (3) a pre-award site review to
identify whether an employer has relocated within the
past 120 days and displaced any of its workers in the
process; and, (3) a definition for "employer pattern of
failure" , steps for corrective action, and the
ineligibility period for an employer who exhibits a
"pattern of failure" .
GJTO' s Recommendation: To fully comply, the SDA needs
to include the definition for "employer pattern of
failure" , steps for corrective action, and the
ineligibility period for an employer who exhibits a
pattern of failure .
Weld' s Response : The Weld County SDA developed an
extensive OJT policy in 1990 and revised that policy to
meet the JTPA amendments . Employment Services of Weld
County will amend its OJT policy to include a definition
of employer pattern of failure, the steps that will be
taken for corrective action, and establish an
ineligibility period for employers who exhibit a pattern
of failure .
2. Higher Education Agreement (HEA) Coordination:
According to PGL # 93-13-P1, SDAs were to develop
coordination information with schools to: (1) avoid
double billing for educational costs; (2) establish a
three party agreement between the JTPA client, SDA, and
school that identifies the portion of the Pell and other
grants to be applied to tuition, fees, and books; and,
(3) ensure that JTPA is the supplemental financial
resource for those receiving Pell and other financial
grants.
The SDA' s policy met all the requirements specified in
PGL # 93-13-P1 .
Page 3 of 14
3 . Monitoring Policy- In JTPA Letter #92-05, SDAs were
required to develop written procedures for monitoring
their internal programs, and monitoring subcontractors .
Procedures were to include annual reviews and written
reports on program activities; and, bi-annual reviews and
written reports for Fiscal, MIS, Procurement, Affirmative
Action/Grievance Procedures, and Administration.
Additionally, JTPA Letter #92-11, establishes PIC
oversight and monitoring responsibilities .
The SDA' s monitoring reports were done on a quarterly
basis for its internal program activities; quarterly
monitoring reports were submitted to the PIC. The SDA has
fully complied with the requirements of JTPA Letters #92-
05 and # 92-11 .
4. Youth Subsidized Employment: PGL # 93-27-C1 identifies
the specifics to be included in these youth policies :
work experience, OJT, limited internship, and cooperative
education. Work experience is to be coupled with basic
skills and/or occupational skills training, and shall be
for a reasonable length of time (as stated on the ISS) .
For OJT see #1 above . Limited internship (LI) is a
private sector work assignment that'.s limited to 500
hours . Cooperative education is limited to 500 hours and
combines work in the private sector with educational
programs . For LI and cooperative education programs, only
economically disadvantaged youth 16 or older may be
placed at private-for-profit work sites.
At the time of this review the SDA' s work experience,
cooperative education, and limited internship policies
were still in draft form ; the OJT policy was final .
No compliance issues were noted during the review of two
LIs and two work experience contracts.
GJTO' s Recommendation: To fully comply with PGL # 93-27-
Cl, the SDA needs to submit the finalized policies for
work experience, limited internships, and cooperative
education.
Weld' s Response : Weld County SDA addressed the
requirements of PGL # 93-27-C1 in its JTP. The policies
for limited internship and work experience will be
finalized and submitted to the State Field
Representative . Weld County does not operate any
cooperative education programs .
5. Formal Agreement with Local Educational Agency:
According to JTPA Letter # 92-11 and Section 265 (a) ,
agreements are to include the following: (1) procedures
Page 4 of 14
for referral of in-school youth, and notification when
youth drop-out; (2) methods of assessment for in-school
youth; (3) definition for "satisfactory progress" ; and,
(4) exchange of information on participants' needs and
progress .
The SDA has signed agreements with all its school
districts . During the review of these agreements and
client files, the monitor evidenced no definition for
"satisfactory progress" .
GJTO's Recommendation: Agreements need to include an
agreed upon definition for "satisfactory progress" .
Weld' s Response : Weld County' s Agreements with local
school districts stipulate that case managers will review
progress of participants with the appointed school
official . Weld County will address the issue of a
definition of satisfactory progress with the Youth
Committee of the Private Industry Council and amend the
Formal Agreements with local school districts if
appropriate.
6 . Bonus and Incentives- In 627.305 (b) (5) (c) , the SDAs
were to develop a formula for youth bonus and incentive
payments, which is based on attendance and/or
performance .
With the limited dollars available for client services,
the SDA chose not to provide bonus and incentive payments
to youth.
B. Interview Questions
This section is comprised of questions addressed to the
SDA from GJTO, and the SDA' s responses .
1. How and when is information describing the "full
array of services" provided to eligible applicants?
During the intake process all applicants receive a
flyer that identifies services provided by the SDA.
After an applicant has been determined eligible
they are scheduled to attend Orientation. At
Orientation eligible applicants are given an
explanation of services and receive a brochure that
details the full array of services offered by the
SDA.
2 . How is it determined that eligible applicants do
not meet enrollment requirements and what records
Page 5 of 14
are maintained to document their referral to
appropriate programs?
Generally, all eligible applicants are enrolled
into objective assessment . However, the SDA may
choose not to enroll an eligible applicant if they
fall into one of the following categories : choose
not to continue, low functioning, medical
conditions and/or multiple barriers that preclude
participation at this time. Eligible applicants who
are not enrolled are referred to an appropriate
agency for services, and their referral is
documented in the case notes .
3 . How are women informed and encouraged to consider
non-traditional occupations?
In objective assessment participants take a battery
of tests to assess aptitude, achievement, and
interests. Female participants discuss test results
with their counselor; non-traditional occupations
are discussed at this time.
GJTO' s Recommendation:
A request to the Capacity Building Committee for a
workshop on non-traditional training could prove
beneficial to staff . The SDA might also consider
using visual aids to deliver their message on non-
traditional employment . Additionally, the GJTO is
available for technical assistance in this area.
Weld' s Response: Weld County has a staff person
that is a member of the Capacity Building Committee
and a request for the development of non-
traditional training workshop has been made . Weld
County has developed a non-traditional training
course for women in the mechanical maintenance
field in cooperation with Aims Community College .
Additionally, other non-traditional training is
encouraged for women who indicate an interest . At
the time of the exit interview for this monitoring,
Weld County requested technical assistance in
obtaining literature on non-traditional employment
for women and related training for staff .
GJTO' s Response :
GJTO will provide the SDA with a list of agencies
that disburse NTO literature. Additionally, GJTO
has contracted with the Colorado Community College
and Occupational Education System to provide NTO
Page 6 of 14
training to the SDAs; the SDA will be notified when
a training date has been scheduled.
4. Describe the assessment/ISS process. What is
initial assessment? What is objective assessment?
How and when is the ISS process completed using
assessment and client input?
Applicants attend Orientation where they fill out
an application and take the Test of Adult Basic
Education (TABE) locator test . Intake workers
review completed applications and reschedule
applicants for a final review of their eligibility
documentation. Eligible applicants are then
enrolled into objective assessment where they are
assigned a counselor.
In objective assessment clients review their work
history, education, family situation, financial
status and supportive service needs with their
counselor. Clients also take a battery of tests to
identify their aptitude, achievement, and
vocational interest areas . At this point the client
and counselor will discuss test results and program
options; clients are then given a career
exploration assignment to do in the community.
While clients could be in objective assessment for
up to six months, enrollment in this activity
rarely lasted longer than six weeks . Upon
completion of the aforementioned tests and
assignments, the client and counselor formulate a
plan of services based on the information obtained
in objective assessment . This plan of services
becomes the clients' Individual Service Strategy
(ISS) .
5. Are participants being terminated after objective
assessment (neutral termination) ? For what reason?
Will any changes be made to initial assessment as a
result?
Lack of interest and/or failure to return to
objective assessment were the only reasons clients
were terminated from objective assessment .
During the file review, the monitor noted that a
significant number of clients appeared to be self-
terminating from objective assessment . Generally,
those who self-terminated appeared to have
extensive barriers that were not addressed prior to
enrollment . After discussing this with staff, the
SDA implemented a change in the initial assessment
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procedure; eligible applicants would no longer be
automatically enrolled. Eligible applicants would
be enrolled after their identified barriers were
addressed.
6. Is the new TAG being used to document eligibility?
Has the incidence of self-attestation increased?
Eligibility was determined based on the require-
ments specified in the new eligibility TAG. Use of
self-attestation was minimal; however, the SDA was
documenting income and family size using self-
attestation when other avenues were exhausted.
7. How does the SDA ensure that every enrollee
receives training or educational services designed
to increase the participant' s basic and/or
occupational skills?
The ISS determined the first activity a client was
enrolled into, which was either a vocational
training program or a basic skills class . Weekly
reports were generated by the Management
Information System (MIS) department to ensure that
clients were enrolled in training as their first
activity. Additionally, supervisors monitored files
quarterly for compliance with Section 204 (c) of
the amended JTPA.
8. What options for school attendance can the SDA
provide to out-of-school youth under age 18 ?
In order to receive services from the SDA out-of-
school youth (who are under 18) must re-enroll into
regular school, alternative school, or a General
Equivalency Development (GED) program.
9. How does the SDA ensure that the pre-
employment/work maturity skills training is
accompanied by other services designed to increase
the basic and/or occupational skills of youth
participants ?
As identified on the ISS, all youth enrolled in
pre-employment/ work maturity were concurrently or
sequentially enrolled in a work experience or an
educational component . Supervisors monitored files
quarterly for compliance with Section 264 (d) (3) (A)
of the amended JTPA.
10. How does the SDA ensure that work experience is
accompanied by other services designed to increase
Page 8 of 14
the basic and/or occupational skills of
participants ?
When work experience was identified for a client,
the ISS identified basic and/or occupational skills
training be provided to the client either
sequentially or concurrently. Supervisors monitored
files quarterly for compliance with 627 . 245 (d) of
the regulations .
III. ELIGIBILITY DETERMINATION/MIS/CLIENT FILES
A random sample of 30 participant files was reviewed during
this compliance procedure. Of the files selected, half
represented youth enrolled into the Title II-C program; the
other half were adults in Title II-A. According to the new
eligibility TAG, each file must contain documentation of age,
family income, family size (when determination is made from
income), barrier identification, citizenship (I-9) , residency
and other pertinent information; and, when applicable,
handicap verification and Selective Service registration.
Files must also include an application, test scores,
Individual Service Strategy (ISS) , referral forms, log notes,
and movement and termination forms .
With the changes brought on by the amended JTPA and the
eligibility TAG, SDAs were to focus on harder-to-serve
individuals, of whom no fewer than 65% of participants were to
have one or more barriers . SDAs were given the option to
select an additional barrier for adults and in-school and out-
of-school youth. Weld' s additional barriers for employment
are: Adults who are single parents; in-school youth who are
at-risk of dropping out of school, and out-of-school youth who
are at risk of not succeeding in employment . Youth barriers
will be documented using supporting statements from schools,
counselor notes, and/or documentation from schools or other
programs which attest to the particular portion of the barrier
that applies to the youth.
Weld County requires 100% eligibility documentation for all
clients prior to enrollment . The MIS department provided a
secondary review for compliance, and checked documentation on
the 65% barriers and the additional barrier selected by the
SDA.
During the sample file review, the Monitor observed signifi-
cant improvement in the quality of client ` log notes,
assessment, and training activities . The SDA' s ISS was quite
comprehensive; however, case managers need to translate
assessment information to show how it relates to the specific
training plan selected for the individual . Several negative
Page 9 of 14
terminations resulted when identified barriers were not
addressed prior to enrollment into training activities . The
SDA may want to consider what client barriers they are able to
serve.
IV. FOLLOW-UP ISSUES
No compliance issues were identified during the PY 92 II-A and
II-B reviews.
IV. TECHNICAL ASSISTANCE
The SDA requested technical assistance in obtaining literature
on Non-traditionalEmployment for Women (NEW) and related
training for staff, and assistance in developing its
justification for providing in-house services .
V. PY 92 PERFORMANCE
Weld County SDA exceeded all PY 92 Title II-A performance
standards . Additionally, the SDA surpassed the program goals
it set in its Job Training Plan. These measurements attest to
the quality program the SDA provided.
VI. FISCAL REVIEW
Scope of Review:
As this was a transitional year for all the SDAs, because
of the implementation of the JTPA Reform Amendments and
the Interim Final Regulation, the concentration of this
fiscal monitoring review was to provide technical
assistance .
A full systems review was conducted last year that
disclosed certain recommendations . This fiscal review
followed-up on those recommendations to determine whether
the SDA had implemented any of them.
In addition, there was discussion regarding the new
fiscal requirements as a result of the Amendments and the
Interim Final Regulation and the State issued Policy
Guidance Letters . The primary areas of review and
conversation included Cost Allocation, Cost Principles,
Program Income, Interest Income, Cash Management, and
Audit - Stand-In Costs .
I . Prior Monitoring Issues - -
A. Recommendations
1 . Written fiscal desk procedures (i .e. , expenditure
Page 10 of 14
reporting, cash requests, review and authorization
process) .
In order to strengthen internal controls, the SDA
needs to develop detailed fiscal procedures. These
procedures need to identify the major functions of
the Fiscal Department including expenditure
reporting, cash requests, review and authorization
processes, etc.
GJTO's Observations During This Review:
The SDA has developed desk procedures including
Cash Expenditure to Reporting and Cost Allocation.
To a great extent the SDA relies on the County
procedures . As new policies or procedures specific
to the JTPA program arise, the SDA should continue
to develop and implement them.
2 . Approval and authorization process by the Director.
Segregation of duties should include the Director' s
approval and authorization with regard to
expenditures. Specifically, the Director should
review, approve and authorize all payments as to
proper cost categories and propriety, and any cost
reclassification journal entries .
GJTO' s Observations During This Review:
The Director still does not sign-off as approving
or authorizing signature on vouchers . However, the
SDA' s Director reviews the expenditures in the
general ledger quarterly. In addition, the
expenditure is authorized by the Case Managers and
approved by the County in addition to the Fiscal
Officer. It appears that the SDA has adequate
compensating controls in place to reduce the need
for the Director' s signature on every expenditure.
3 . Match supporting documentation.
Backup documentation for "match invoices" needs to
be maintained at the SDA. Documentation may
include time sheets for match of personnel, rent
billings to document space costs, etc .
GJTO' s Observations During This Review:
The SDA maintains the match invoices and plans to
monitor the contract to verify the match invoices .
Page 11 of 14
B. Observations
1 . Internal Services Printing Expenditures .
In order to improve internal controls, GJTO
recommended that the SDA implement an internal
service printing authorization form prepared by the
person requesting the documentation, and approved
by that person' s supervisor. In addition, we
recommended that all printing orders to the County
have an approval by the authorized person' s
supervisor.
GJTO's Observations During This Review:
The SDA has developed a printing expenditure form
so that the process
in not controlled by just one person. This
observation has been implemented.
2 . Time Sheet Review.
As an indication of approval and authorization, all
time sheets should be signed and dated by both the
employee and their supervisor.
GJTO' s Observations During This Review:
The SDA has suggested that the signing of time
sheets is done on a more consistent basis now that
they are required on a monthly rather than a weekly
basis .
II. AMENDMENTS AND INTERIM FINAL REGULATIONS
A. Cost Allocation
The cost allocation systems and processes appear to be
operating properly. The SDA has developed a new time
sheet that all employees complete, which segregates their
time into the new JTPA cost categories. The SDA has
summarized the activities that fall under each of the
cost categories on the back of the time sheet according
to GJTO' s Cost Principles Policy Guidance Letter.
GJTO'B RECOMMENDATION
GJTO recommends that the SDA weight the time worked by
the rate of pay of each respective employee, which should
result in a truer cost allocation and "benefits
received" .
Page 12 of 14
SDA's Response: Weld County SDA has initiated the
recommendation of GJTO and has a formula which weights
the rate of pay and time worked for employees and is used
in the cost allocation plan.
GJTO' s Response: GJTO accepts the SDA' s response to the
recommendation.
B. Program Income
There was a general discussion on whether the Learning
Lab generates program income. The SDA should document
this issue in policy or in the Job Training Plan.
C. Cash Management
The SDA is still on a reimbursement basis .
D. Audit - Stand-in Costs
There was a discussion on stand-in costs . As stand-in
costs provide the SDA and the County with an "insurance
policy" for disallowed costs, the GJTO highly recommends
that the SDA continue to document and report stand-in
costs according to GJTO' s Audit PGL #93-11-F6 and Fiscal
Procedures.
III. TEST OF TRANSACTIONS
The test of transactions was not performed during this
year' s review, as last year' s review disclosed minimal
exceptions .
IV. SUMMARY:
We' d like to thank all the staff, especially the Weld
County Human Resource Fiscal Officer, for their attention
and concern for the matters at hand during this review
and hope that this review assisted with your transition
to meeting the requirements of the JTPA reform
amendments, regulations, and state policies .
VII . PROCUREMENT REVIEW
Need written procurement procedure which includes cost
and price analysis, estimate, etc. Weld SDA will be in
compliance with Policy Guidance Letter #93-02-AD1,
"Procurement Policy; " :once these documents are received
by GJTO.
Page 13 of 14
GJTO recommends the following:
o Centralizing procurement files or keeping a central
procurement file including procedures and sole
source, vendor selection; and
o Ensure "independent estimates" are made prior to
bids, need to add a place for this on the current
forms.
GJTO would like to thank Marilyn Carlino for her time and
assistance on this review.
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