HomeMy WebLinkAbout930983.tiff STATE OF COLORADO
GOVERNOR'S JOB TRAINING OFFICE
J Fe 90
720 South Colorado Blvd.,Suite 550 (�,� o
Denver,Colorado 80222
Phone(303)758-5020
FAX(303)758-5578 —
Roy Romer
Governor
Leslie 5. Franklin
Director
May 5 , 1993
Ms . Contance Harbert
County Commissioner
P. O. Box 758
Greeley, Colorado 80632
Dear Ms . Harbert :
Attached is the final monitoring report of the Program
Year 1991 ( PY 91 ) and the first quarter PY 92 Title II-A
Systems and Compliance Review of the Weld County Depart-
ment of Human Resources .
This review was conducted during December 1992 , by the
Governor ' s -Job Training Office, in compliance with the
job Training Partnership Act, Section 164 .
Sincerely ,
LesiNi\e.S� . Fr tin
Direcbo'r
Attachment
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S30983
Yfi;`1 I 1 Y\CA?
Monitoring Report
SDA: Weld County Department of
Human Resources
P.O.Box 1805
Greeley, Colorado 80631
Program: II-A Program Year 1992
Period of Performance: July 1 , 1991 - September 30 , 1992
Monitoring Dates: December 1-4 , 7-9 , and 12 , 1992
Monitor(s) : Elise Lowe-Vaughn State Field Rep.
Kathy Workman Program Monitoring
Unit Manager
Elizabeth Pokorney MIS Clerk
Juanita Berry EDWAA Planner
Scott Toland Fiscal Monitor
Thirza Kennedy Purchasing Agent
SDA Staff Involved: Linda Perez Director
Ted Long Employment & Training
Coordinator
Marilyn Carlino Fiscal Officer
Jim Harrington Data Systems Clerk
I. INTRODUCTION
A Program Year 1991 (PY 91 ) and first quarter PY 92 compliance
review of Weld County Department of Human Resources , Service
Delivery Areas (SDA) Title II-A Systems was conducted at the
Administrative Office on December 1 , 1992 . Representatives from
the Governor' s Job Training Office (GJTO) conducted the on-site
review.
The SDA Director, Ms . Linda Perez , assigned appropriate staff to
provide the necessary information for the review.
The review covered the following general areas :
Section 1- Monitoring Policy
Section 2- Fiscal
Section 3- Procurement
Section 4- Eligibility Determination and Management Information
Systems (MIS )
Section 5- Administration
Section 6- Program Activities
- Assessment and Referral
- Outreach and Recruitment
- Youth Competencies
Methodology included :
* Use of the GJTO Monitoring Guide;
* Discussion with appropriate staff; and a
* Review of client files and other pertinent documents maintained
by the SDA.
II . SUMMARY OF FINDINGS
During the past year Weld County Department of Human Resources
initiated significant changes in their outreach, recruitment, and
orientation processes . These changes were reflective of the SDA ' s
commitment to improving program quality, as evidenced by the SDA
exceeding all performance standards . Technical Assistance was
requested by the SDA from the GJTO and the U.S . Department of Labor
(USDOL) for orientation, initial assessment, and Employability
Development Plan (EDP) refinement. Since the previous review, the
Monitor noted substantial improvement in EDPs , log notes , and
recruitment of non-welfare applicants .
Weld County has an excellent monitoring policy . All staff levels
( including the PIC) are involved in reviews ; clients are involved
as well . Reviews are conducted frequently .
While no compliance issues were evidenced during this review, the
following areas need to be strengthened . Fiscal policies and
procedures need to be developed , and segregation of duties needs to
be revised to add more internal controls . Many files lacked
specific documentation of competencies achieved . End of program
and 90-day holds need to be reviewed . JASR reports need to reflect
all training activities .
III. SYSTEMS REVIEW
A. Monitoring
In accordance with JTPA Letter #89-12 , the SDA developed and im-
plemented a monitoring policy, approved by its Private Industry
Council, by the end of first quarter PY 92 . This policy covered
all requirements except it failed to incorporate the development of
a Supportive Services monitoring policy .
The SDA' s policy requires supervisors to review 10% of active
caseloads a month using a file review checklist that will be
maintained either in a central monitoring file or the client ' s
permanent file. This evaluation includes eligibility and support-
ing documents, EDPs, and the assessment of program activities
including appropriateness , the accomplishment of goals and time
frames , and the quality of case notes . This evaluation form
requires the user to check either yes or no for each area reviewed ,
yet the criteria used to determine whether compliance was met was
unspecified . Corrective action will be documented and a follow-up
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review will be done. Testing and data entry will be reviewed bi-
weekly .
Case Managers and client technicians will monitor basic education,
classroom training, and job club at least once every four weeks , or
at least twice if the activity exceeds four weeks . The evaluation
includes time and attendance, instructional materials , pre/post
tests , competency attainment, adult and youth program procedures ,
successful outcomes of activities , and an evaluation by partici-
pants . Supervisors will monitor these activities twice during the
year . Evaluation forms will be kept in the client ' s file .
Work experience, On-the-Job training, and work training sites used
for competencies will be monitored at least once by a Case Manager
other than the one who wrote the training contract . Monitoring
will occur during the first month of the activity except at new
sites where monitoring will occur within the first 2 weeks . The
areas reviewed will be: JTPA compliance, time and attendance,
documented progress , adherence to the job training outline,
outcomes ( including competency achievement ) , contract accuracy, and
the client ' s program activity evaluation .
Supervisors will select two files per Case Manager per year using
a monitoring form. Corrective action will be taken for compliance
of safety issues , and follow-up will be done within one week.
Should compliance issue( s ) arise, the activity will be suspended
until compliance issue( s ) are resolved .
The Fiscal Department will monitor and evaluate program payroll and
invoicing procedures once a year , and external contracts and
agreements quarterly . Procurement will be reviewed yearly to
ensure compliance with County and GJTO procurement policies .
Administrative findings will be reviewed for timely resolution of
the corrective action. Grievance procedures will be monitored
yearly . Affirmative action will be monitored quarterly by the
Director .
Supervisors will review performance standards monthly to evaluate
planned and actual performance for placements , affirmative action,
activities , and criteria specified in the Job Training Plan .
The PIC will monitor performance standards quarterly for effective-
ness in meeting planned goals and performance, and for all external
contracts and agreements . The SDA will provide monitoring
summaries to the PIC; the PIC will provide input on compliance and
corrective actions .
GJTO' s Recommendation:
1 . The SDA needs to develop a supportive service monitoring
policy, as required by JTPA letter #92-05 .
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SDA' s Response:
The Weld County SDA developed a monitoring policy as required
by JTPA Letter #92-05 . The Supportive Services ' monitoring
policy was not addressed , however, the current policy will be
modified to include supportive services .
GJTO' s Recommendation:
2 . The monitoring checklist would be more user friendly if
it identified what criteria were used to warrant a yes or
no answer on the form.
SDA' s Response:
Guidance will be provided to staff on criteria to use for
completing the form.
B. Fiscal
A fiscal review of second quarter PY 91 through end of first
quarter PY 92 was conducted using the newly developed pre-award
site review instrument and a cash disbursement test . This review
assessed whether the SDA had adequate fiscal policies , procedures ,
and controls to assure for the proper disbursal of and accounting
for of JTPA funds . The instrument assessed the amount of potential
risk involved with each major aspect of accounting controls .
In the area of cash management, the SDA had adequate standardized
controls . Written policies and procedures were in place. Internal
controls covered bonding, separation of duties , frequency of cash
reconciliation, method and authorization of check signers , specific
transaction dollar limits , and petty cash funds . The SDA is
insured and collateralized with banking institutions , and has cash
depository coverage. No excess cash was on hand , and no interest
income was earned .
The SDA does not generate program income from JTPA funds .
Adequate insurance coverage was secured .
Policies and procedures for equipment purchases were in place and
followed JTPA Letter #90-23 .
The SDA is considered a major program by the County . Annual audits
are conducted in accordance with OMB Circular A-128 and are
forwarded to GJTO. No services were subcontracted out by the SDA.
The lack of written procedures for cash requests and expenditure
reporting poses some risk for the SDA.
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While the SDA follows accounting procedures prescribed by the
County, there were no specific desk procedures which addressed the
JTPA grant. In addition, approval and authorization of specific
expenditures ( vouchers ) was not segregated .
The SDA meets contract reporting requirements and maintains appro-
priate supporting documents . Management reviews and approves
financial reports .
Match funds for 8% contracts were recorded and tracked; however,
supporting documentation was not maintained by the SDA.
The SDA has an approved cost allocation plan. While the Fiscal
Officer and the County review cost classifications prior to
authorizing payments, no secondary review is preformed to assure
for reasonableness , necessity, allowability, and allocability of
the expenditure. The SDA is at risk when only one person has this
responsibility; therefore, to promote a viable segregation of
duties, it is recommended that the Director ' s signature be added to
the final approval process .
The Director and Fiscal Officer are versed in cost category
limitations . Should an entry be made in a wrong category, the
Fiscal Officer and the County would authorize a cost reclassi-
fication journal entry.
During the cash disbursement test, the following observations were
noted . Most time sheets were signed but were not dated by the
supervisor or employee, and in a few instances , time sheets lacked
a supervisory signature. Printing expenditures for internal
services were authorized , ordered , and recorded by one person .
Hotel accommodations for a JTPA conference the Director attended
were charged to the training cost category . The Fiscal Monitor
questioned why this cost was not charged to the administrative cost
category. The issue was resolved; the County reimbursed the SDA
account for those funds .
GJTO' s Recommendations :
1 . 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 re-
quests , review and authorization processes , etc.
SDA' S Response:
The Weld County SDA follows fiscal procedures defined in the
Weld County Administrative Manual . These procedures are not
specific to program. Specific procedures have been written to
address specific grant functions; i . e. , cost allocation plan,
client payrolls , OJT process , etc. However, other specific
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fiscal procedures that are not already covered will be written
and in place by June 30 , 1993 .
GJTO' s Recommendation:
2 . 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 .
SDA' s Response:
Client expenditures have been segregated and area approved to
program by the Case Managers . The Fiscal Director assigned
cost classifications . The Director will monitor the authori-
zation and approval process with regard to expenditures
randomly on a monthly basis to determine if additional
processes need to be implemented .
GJTO' s Recommendation:
3 . Backup documentation for "match invoices" need to be
maintained at the SDA. Documentation may include time
sheets for match of personnel , rent billings to document
space costs , etc .
SDA' s Response :
The Weld County SDA Fiscal Department will monitor the match
agency and verify the accuracy of the match and provide a
written verification for the match invoices .
C. Procurement
The SDA has adequate procurement policies , procedures , and controls
to ensure full , open, competitive and equitable procurement of JTPA
goods and/or services . All procurement is secured through the
County whose process is more restrictive than the State ' s .
D. Eligibility Determination/MIS/Client Files
A random sample of 35 participant files was reviewed during this
compliance procedure. Of the files selected , half represented
youth who had been or were currently enrolled in youth competency
programs , the other half were adults in various program activities .
According to JTPA Letter #90-07 each file must contain documenta-
tion of age, family income, family size (when determination is made
from income) , citizenship ( I-9 ) , residency and other pertinent
information; and , when applicable, handicap verification and
Selective Service registration. Files must also include an
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application, test scores , Employability Development Plans (EDPs ) ,
log notes , and movement and termination forms .
Weld County requires 100% eligibility documentation for all clients
prior to enrollment. The MIS Department provided a secondary
review for compliance.
During the sample file review, the Monitor observed significant
improvement in the quality of client log notes and EDPs . And ,
while files contained the required data, the following observations
were noted. Several income eligible clients had wage inquiries in
their files which failed to note the date the inquiry was run.
Several in-school youths files lacked updated EDPs or failed to
have the youth' s signature. Two youth files showed the youth as
enrolled in training to develop marketable skills training;
however, the files lacked any documentation as to what had
transpired during the four months these youth were enrolled in this
activity . And , with the current program focus on longer term
training, the adult "average weeks in all training" appeared quite
low.
GJTO ' s Recommendations :
1 . When eligibility is determined based on family income,
wage inquiries should be used consistently for all
members in a household , identified according to the
specific time frames covered, and signed by appropriate
staff.
SDA' s Response :
weld County agrees with the recommendations .
GJTO' s Recommendation:
2 . EDPs need to be signed by clients , and updated regularly .
SDA' s Response:
It is Weld County ' s policy that all EDPs be signed by clients
and updated regularly . Staff will be reinformed of this
policy and monitored by supervisors .
GJTO' s Recommendation:
3 . Training to develop marketable work habits must be
verifiable as an on-going training activity based on
either log notes or classroom paperwork, and identified
on the EDP. The SDA needs to monitor this activity to
insure compliance with JTPA letter #90-24 .
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SDA' S Response:
The Weld County SDA agrees to actively monitor the training to
develop marketable work habits to insure compliance with JTPA
Letter #90-24 .
GJTO' s Recommendation:
4 . The SDA needs to review how training codes are effecting
"average weeks in all training" and "average weeks in
title training" on the JASR.
SDA' s Response:
The Weld County SDA reviewed the activity categories and found
one training activity that was not transferring correctly .
This area was corrected in the system.
E. Administration
The SDA' s organizational structure reflects lines of authority and
responsibility , however it fails to identify the specific staff in
each unit.
Systems are in place for disseminating federal , state, and local
policies to appropriate staff. Copies of these documents are kept
in a central policy library .
Personnel policies are complete . The SDA is handicap accessible .
Grievance procedures were provided to all applicants and included
discrimination complaint procedures for individuals with disabil-
ities . The SDA' s discrimination complaint procedure for individu-
als with disabilities inaccurately listed the USDOL . All non-
discrimination requirements were in place .
The PIC structure and the PIC/LEO agreement were in compliance with
the law.
Planning and coordination of services were monitored regularly by
staff. Special attention was paid to recruitment of significant
segments and target groups . Coordination with other agencies has
been expanded in an effort to reach a larger target population.
Reporting and record retention were deemed adequate.
GJTO' s Recommendation:
1 . The SDA needs to revise its organizational chart to
include staff in each department .
Page 8 of 11
SDA' s Response :
The SDA has organizational charts which include staff in each
department . A copy has been provided to GJTO.
GJTO ' S Recommendation:
2 . Under discrimination complaint procedures for individuals
with disabilities the SDA needs to make the following changes :
Steps 1 and 4 - change Assistant Secretary of USDOL to the
Directorate of Civil Rights .
SDA' s Response:
The Weld County SDA will make the changes recommended .
F. Program Activities
1 . Assessment and Referral
The SDA assessed eligible applicants using the Adult Basic
Level Equivalency (ABLE) pre-screening tests . Results from
these tests , coupled with a barriers interview conducted by
the Case Manager, help determine the client ' s ability to
benefit from the program. Upon enrollment, the client meets
with the Case Manager to initiate this joint Employability
Development Plan (EDP ) . Should it become apparent that
further assessment is needed to complete the EDP, the client
may be referred for further assessment for aptitude, vocat-
ional interests , or physical dexterity tests . Compiling the
assessment information, along with the client ' s past employ-
ment experience and transferrable skills , the EDP becomes the
working plan for all activities in which the client is
enrolled . If a change of direction is needed , the Case
Manager and client jointly revise the EDP to incorporate any
programmatic changes . All EDPs are signed by the client and
Case Manager; a copy of the document is given to the client,
and the original is placed in the client ' s file. During the
past year, the SDA enlisted technical assistance from the GJTO
and the USDOL for developing an EDP that was more user
friendly, and identified and addressed resolution of barriers
prior to a client ' s start into an activity .
In accordance with JTPA Letter #92-05 , the SDA implemented a
monitoring policy which included reviewing the process of
client assessment and referral .
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2 . Outreach and Recruitment
The SDA expanded their outreach and recruitment process to
increase employer and public awareness to the varied programs
and services available through the use of a media kit and
brochures . Originally, the SDA' s primary target group was
welfare recipients; the SDA has since expanded client recruit-
ment to include handicap individuals , drop-outs , food stamp
recipients , unemployment insurance recipients , and older
workers . Coordination agreements were developed with the
local public schools, community-based organizations , and
groups like the Greeley Dream Team, Educational Opportunity
Center, Aims Community College, and Right-to-Read to insure
that targeted groups were reached .
Since expanding their target groups , the SDA revised their
orientation process to elaborate on available JTPA services
and included a one-page questionnaire to help identify
potentially eligible individuals .
3 . Youth Competencies
The SDA provided competency training for in-school and out-of-
school youth. Competency training was available in three
areas : pre-employment/work maturity, basic skills , and job
specifics . Specific competency training was developed in
accordance with JTPA Letter #89-12 . Youth were identified for
competency training based on pre-test scores and their EDPs;
competencies were awarded based on post-test improvements as
certified by the PIC.
Competency curricula were generally good . Training outlines
identified quantifiable objectives required for a youth to
achieve a competency; however they lacked curriculum specifics
such as the minimum duration of training (days/hours ) needed
for an individual to achieve a competency .
Pre-employment/work maturity classes ranged between 160 and
250 hours . Job specific course work lasted up to 250 hours ,
and Basic Skills was self-paced and based on improvement of at
least two grade levels , and/or attainment of a GED or diploma.
An excellent competency checklist was developed to record
pre/post test scores and identify competencies achieved . The
SDA is currently revising its pre/post tests .
All client files contained an EDP , pre/post-tests , and a
certificate if a competency was achieved . While competency
certificates identified specific areas of competency achieve-
ment, it was difficult to determine the overall competency
attained . During the file review, the reviewer found it
difficult to determine what paperwork was related to an
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overall competency. In a few cases , it was difficult to
determine how the SDA documented the 120 school days required
for the SDA to claim a return to full time school termination
and receive a basic skill competency.
GJTO' s Recommendation:
1 . Competency certificates could be more readily identified
if the specific competency achieved was listed at the top
of the certificate.
SDA' s Response :
The competency certificates will be modified to list the
competency achieved at the top of the certificate .
GJTO' s Recommendation:
2 . The development of a checklist, in each client ' s file,
would help the Monitors identify what paperwork was
specific to each competency attained .
SDA' s Response:
Staff will review the checklist concept to determine the
feasibility of including a checklist in each file.
GJTO ' s Recommendation:
3 . When claiming remained in full time school , the SDA needs
to find a way to document that the youth remained in
school and made satisfactory progress for one semester or
120 days; returned to full time school must also have
similar documentation.
SDA' s Response:
The Weld County SDA will assure that an outcome of
remained in school or returned to full-time school will
have appropriate documentation.
SDA' s Response:
4 . The SDA needs to strengthen its competency training
manuals to include formalized curricula, with training
modules targeted for the specific competencies in which
the youth is deficient .
SDA' s Response :
The SDA will strengthen its competency training manuals to
include examples of the curricula .
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