HomeMy WebLinkAbout20174128.tiffCOLORADO
Department of
Labor and Employment
November 22, 2017
Julie Cozad
Weld County Commissioners
1150 O Street
Greeley, CO 80631
Dear Ms. Cozad:
Workforce Development Programs
633 17th Street, Suite 201
Denver, CO 80202-3660
RECEIVED
DEC 0 5 2017
WELD COUNTY
COMMISSIONERS
The Colorado Department of Labor and Employment (CDLE)/Workforce Development Programs conducted the
annual compliance review of the Employment Services of Weld County (ESWC) from September 11 to September
15, 2017. The review encompassed Workforce Innovation and Opportunity Act, Trade Adjustment Assistance,
Wagner-Peyser, Employment Support Fund, and discretionary grants for the period July 1, 2016 through June 30,
2017. The review was performed in accordance with CDLE Policy Guidance Letter (PGL) ADM -2015-02, Change 1.
Enclosed please find the Final Annual Compliance Monitoring Report for PY16 prepared by the Colorado
Department of Labor and Employment - Workforce Development Programs.
We would like to thank the staff at the ESWC for the assistance they provided to the State Workforce Monitors
during all phases of the review. The staff were courteous and their professionalism during and following the review
was notable.
If you have any questions, please contact your Regional Liaison, Andrew Galloway, at 303-318-8840 or
andrew.galloway@state.co.us.
Sincerely,
Elise Lowe -Vaughn
Workforce Programs, Policy and Strategic Initiatives Director
cc: Tami Grant, Employment Services of Weld County Director
Dave Thompson, Workforce Development Board Chair
633 17th Street, Suite 201, Denver, CO 80202-3660 P 303-318-8000 I www.colorado.gov/cdte
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2017-4128
COLORADO
Department of
Labor and Employment
Workforce Development Programs
Regional Services Unit
633 17th Street Denver, CO 80202
Local Workforce Area Annual Program Monitoring Report:
Employment Services of Weld County
Main Office Location: 315 N. 11th Ave., BLDG B PO Box 1805
Greely, CO 80632
Period of Review: 7/1/2016 to 6/30/2017
Date Issued: 11/28/2017
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO
Department of
Labor and Employment
Executive Summary
Purpose/Methodology: The Workforce Development Programs (WDP) Regional Services Unit
(RSU) conducts program monitoring, in compliance with Program Guidance Letter (PGL) ADM -
2015 -02 Performance and Compliance Review Process, on organizations that receive funds
through CDLE to operate workforce programs, discretionary grants, and specialized grants. The
purpose of monitoring is to ensure that programs operate in compliance with federal and state
guidelines. Monitoring activities include questionnaires, analyzing program and fiscal data, and
client case file reviews. Program. Monitoring categories include Governance, Administrative/
Program/Grant/Fiscal Management, Delivery Systems/Documentation, and Performance
Accountability.
Programs/Funding Streams Under Review: All Title I funding streams that are part of the
Workforce Innovation and Opportunity Act (WIOA), Wagner Peyser (WP), and various
discretionary grants that have been funded using federal/state funds. See section 3 for a
comprehensive list of programs under review.
Promising Practices and Notable Achievements:
Employment Services of Weld Count (ESWC) brought back the Weld Works 4 Youth Summer
Employment program this year, and had great success placing youth into summer employment.
Through this program, 74 youth submitted applications and placed 42 youth into summer
employment opportunities, 35 of whom successfully completed the internship. Eight (8)
workshops were developed as part of the summer employment program to help youth be
successful throughout the entire program. The program was funded by the Temporary
Assistance for Needy Families (TANF) program, and helped 14 and 15 year old in -school youth
participants gain work experience.
ESWC has developed a Work Based Learning cross -functional team made up of staff from TANF,
Employment First, all Title I WIOA programs, and Business Services staff. The cross -functional
team is tasked with establishing work based learning opportunities for customers across all
partner programs throughout ESWC. The team communicates with businesses to address the
skills gap issue with new and existing employees. The Work Based Learning Cross -functional
team helps raise awareness of work -based Learning opportunities in Weld County.
During the Sector NEG grant review, it was evident the ESWC used its partnership with Links to
Reemployment and Reemployment Services and Eligibility Assessment (RESEA) to recruit
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Program Year 16
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Department of
Labor and Employment
eligible participants for the Sector NEG program. From the sample reviewed, 8 of the 10
participants were enrolled as direct referrals from RESEA, which demonstrates a promising
practice of leveraging partner programs.
The Initial Assessments, Comprehensive Assessments and Individual Employment Plans used in
the Adult, Dislocated Worker and Youth Programs assist staff in collecting in-depth information
to ensure proper services are provided to participants. Collecting this critical data at the
beginning of the participants' experience enables caseworkers to more effectively provide
services that prepare jobseekers for success in meeting the needs of employers and obtaining
sustainable employment.
Review Results:
Program Monitoring is used as a tool to enable Local Area workforce providers to serve
Colorado businesses and job seekers at the highest level. CDLE strives to ensure program
reviews identify areas of strength and areas for improvement. After review of the ESWC
programs, the following areas offer potential opportunities for CDLE and ESWC to collaborate
and enhance service delivery for clients in Weld County.
• Governance
o The Weld County Workforce Development Board (WDB) met the October 1,
2016 deadline for compliance with WIOA membership requirements.
• Administrative Systems
o No areas of concerns
• Program Services, Delivery Systems, and Documentation
o No compliance issues identified
o No action items
o One (1) observation
• Case files indicate that solid assessment services are provided to program
participants. Basic skills, computer literacy, and career aptitude
assessments are utilized. Barriers to employment are identified and
addressed. Case managers take a proactive approach to ensure regular
contact is made with participants during training, job search activities,
and confirming employment/wage information during follow up.
o Two (2) Recommendations
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Program Year 16
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Department of
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• 11 of 49 files reviewed in the Sector NEG, TAA, Hire for Colorado, and
Dislocated Worker programs contained issues with missing or inadequate
documentation of services. CDLE recommends reviewing Data Integrity
and Customer Participation Cycle procedures to ensure correct
documentation of services within Connecting Colorado, as referenced in
PGL-MIS-2012-01
• Data integrity issues in relation to start/end dates of training programs,
missing or insufficient documentation, and missing service codes. CDLE
recommends reviewing internal monitoring processes to include quality
control review of case files to prevent these data integrity issues in
accordance with PGL-MIS-2012-01
• Performance Accountability
o One (1) Compliance finding
• ESWC only expended 49% of the Dislocated Worker program funds and
did not meet the program's required minimum threshold (55%).
o Two (2) Areas of concern
• Two programs (Adult and TAA) failed to meet the 70% expenditure goal
but did not go below 56%, therefore these programs are considered an
area of concern as referenced in PGL-ADM-2015-02, change 2. All
expenditures for PY17 will be monitored as part of a technical assistance
plan to assist ESWC in addressing this issue.
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO
Department of
Labor and Employment
Monitoring
Program Monitoring is conducted in accordance with Policy Guidance Letter (PGL) ADM -2015-
02, Change 1, Performance and Compliance Reviews. See attachment 8 for Risk Assessment
Categories and attachment 9 for Definitions of Key Terms. The PGL and all supporting
documents can be found on-line at https://www.colorado.gov/cdle/pgl.
Section 1: Prior Year Report Follow Up: During the PY15 monitoring review conducted in
September 2016, ESWC was assessed at a low risk level in Governance, Administrative, Delivery
Systems/Documentation and Performance Accountability categories.
Section 2: Workforce Governance & Administration: The Governance review covers the local
workforce area's Workforce Development Board (WDB) and standing committees, Memoranda
of Understanding (MOUs) with required partners, One -Stop Operators and Designation, and
Strategic Planning.
No Governance -related compliance issues were identified. The Weld County WDB met the
October 1, 2016 deadline for having a WIOA-compliant membership roster.
The Administrative, Program/Grant, and Financial Management Systems review covers
reporting systems, internal and subcontractor monitoring, policies and procedures, and
financial audit findings.
The Regional/Local Area Plans are posted online at
https://www.colorado.gov/pacific/cwdc/regional-and-local-plans.
Workforce Development Board Review: Governance
. Review Result: No areas of concern were identified
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO.
Department of
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Section 3: Program Reviews: The Program Services, Delivery Systems, and Documentation
review is an analysis of sampled case records and program questionnaires to ensure compliance
and quality of service delivery systems for employers and job seekers.
ESWC operates the following grants and programs under a grant agreement with CDLE and are
subject to the annual compliance review:
• WIOA Title I Adult, Dislocated Worker, and Youth programs - these programs are the
foundation of the federally funded workforce system that targets each of the identified
groups with specific eligibility criteria.
• WIOA Title III Wagner-Peyser - this federally funded program provides resources to
establish/maintain a nationwide system of One -stop centers that offers workforce
programs to jobseekers and employers.
• Hire for Colorado - is an initiative developed by the Governor's office to provide
specialized services to Colorado jobseekers that have been unemployed for 13 weeks or
longer.
• Trade Adjustment Assistance (TAA) - is a federal program that provides a path for
employment growth and opportunity through aid to US workers who have lost their jobs
as a result of foreign trade.
• Sector NEG - is a national emergency grant to help states develop innovative
employment and training services that focus on enhanced regional and industry -specific
collaborations. The effort is designed to support proven strategies to help people rejoin
the job market and add fuel to the economy.
• Re-employment Services and Eligibility Assessment (RESEA)- is an initiative that targets
claimants who would most benefit from reemployment services earlier in their claim
cycle
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
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Department of
Labor and Employment
One hundred and eight (108) participant files and forty (40) job orders were reviewed by the
Regional Services Unit (RSU) monitoring team.
Program Review: Sector NEG, TAA, Hire for Colorado, and Dislocated Worker
Review Result: Recommendation
Of the forty-nine (49) files reviewed, eleven (11) demonstrated improper use of Job
Search assistance (JS) service code. Case managers reported a JS service after leaving a
voice mail message with job announcement information for a participant. This type of
action is considered administrative in nature, and not a staff -assisted service activity.
When information was communicated in this manner (i.e. without direct discussion or e-
mail interaction with a participant), the case notes did not reflect whether the
participant responded to or read the information that was transmitted. The Connecting
Colorado definition of the JS service specifically states:
"Helping customers look for available job openings, or assisting customers with
the application process. This would include searching for and reviewing job
orders posted in resource centers, on employer websites, on job -search
websites, as well as jobs posted in the Connecting Colorado database. This
service may be entered when any job search assistance is provided, even if the
assistance does not result in a referral."
When providing JS services, CDLE recommends that case managers engage directly with
participants, whether in person or by phone or e-mail, to assist them in finding
appropriate employment opportunities or applying for such opportunities, as outlined in
their Individual Employment Plans, and appropriately documenting the services
provided in the case notes. In other words," job search assistance" requires direct
engagement with the participant; passive engagement, such as leaving a voice mail,
does not meet the definition of "job search assistance" as it relates to WIOA program
case management.
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Program Guidance Letter MIS -2012-01 Guidance on Data Integrity and the Customer
Participation Cycle for WIA and TAA Programs, Attachment 1
Local Area Response:
ESWC will take this under consideration. Based on the definition of the JS service in Connecting
Colorado, there is no reference to a requirement that for a job search service to be considered as
a staff assisted service the customer must confirm the receipt of the referral made.
In addition, the Public Comments portion of the Final Rule at §677.150(a) replaced the phrase
"staff Assisted" with "services other than those described in §677.150(a)(3) [identification of
what constitutes self-services or information only services). Based upon that comment and
information included at §677.150(a)(3) in the regulations which identify what constitutes a non-
participant, the JS services would indicate there was staff involvement in email referrals.
Specifically, JS activities would be considered as information -only services ONLY IF the referrals
did not require an assessment by the Workforce Center staff member regarding the participant's
skills, education, or career objectives. Furthermore, regulations at §677.150(a)(3)(ii)(B) state
"Self Service does not uniformly apply to all virtually accessed services. For example, virtually
accessed services that provide a level of support beyond independent job or information seeking
on the part of the individual would not qualify as a self-service." ESWC believes WIOA
regulations support that if a case manager expends time in completing an evaluation of job
listings to identify listings that meet the career objectives of the customer as well as that the
customer meets the skill and educational requirements of the job and then emails referrals to
the customer that would constitute a Staff Assisted service rather than be determined as a Self -
Service. Thus, it would seem IS services and referrals that involve staff time and effort that are
provided beyond independent job or information seeking would constitute a staff assisted
service.
CDLE Response: CDLE concurs with ESWC as to the definition of a "staff -assisted" service. CDLE
looks forward to working in partnership with ESWC on using case notes to fully document the
level of staff involvement with participation services.
Program Review: WIOA Adult, WIOA Dislocated Worker, Youth, Sector NEG
Review Result: Reccomendation
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO
Department of
Labor and Employment
Of the eighty-three (83) files reviewed, thirteen (13) contained one or more data
integrity issues, including start/end date discrepancies of training programs, missing or
insufficient documentation, and missing service codes. Although these issues were
corrected on site, it was observed as a trend across programs. CDLE recommends
reviewing the Local Area internal monitoring process to include quality control review of
case files to prevent these data integrity issues.
Program Guidance Letter MIS -2012-01 Guidance on Data Integrity and the Customer
Participation Cycle for WIA and TAA Programs, MIS -2016-02 Program Year 2015 (PY15) Data
Validation Procedures, Attachment 1, 2, ADM -2001-01 WIA Internal and Subcontractor
Monitoring
Local Area Response: Weld will take this recommendation under advisement and will explore
strategies designed to bolster internal monitoring reviews.
CDLE Response: CDLE accepts ESWC's response
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO
Department of
Labor and Employment
Section 4: Annual Performance Indicators
The Performance Accountability review covers resolution of compliance issues, budget
expenditure rates, achievement of planned program activity and expenditure goals, and
performance outcome measures.
Weld PY16 Performance
Planned Participants
Actual Participants
Performance
Adult
231
278
120.35%
Dislocated Worker
164
135
82.32%
Youth
193
223
115.54%
Tot
588
6
Must achieve 80% or higher
Work Based Learning
Transitional
Jobs
Incumbent
Worker
Job
Shadowing
Work
Experience
(Pd)
Work
Experience (Unpd)
Apprenticeship
On -the -
Job
Training
Summer
Employment
Adult
0
0
0
9
0
0
1
0
Dislocated
Worker
0
0
0
0
0
1
0
0
Youth
0
0
0
37
0
0
1
0
,'
For PY16 ESWC met or exceeded all performance goals. However, ESWC failed to meet the 70%
expenditure requirement in Dislocated Worker (49%), Adult (57%), and TAA (60%). The low
expenditures in Adult and TAA are considered an area of concern and not a compliance finding
because they were above 55% expenditure. However, the 49% expenditure in the Dislocated
Worker program is a compliance finding. ESWC was aware of the low expenditure and is
already working to address this issue. CDLE will work with ESWC to monitor expenditure in all
programs through PY17 to ensure that spending is on track to achieve the 70% goal for all
programs. A Technical Assistance plan has been developed in partnership between ESWC and
CDLE and will be monitored on a monthly basis. The plan will include the following:
10' Page
Employment Services of Weld County Annual Monitoring Report
Program Year 16
COLORADO
Department of
Labor and Employment
• Increase spending caps for targeted in -demand industry sectors from $2500 to $4500
• Internal leadership change to align all state and federal grant programs and increase
fiscal monitoring from a program perspective and increase outcomes
• Continued partnership with RESEA to increase DW participants enrolled to receive
services
• Committed Work Based Learning team to increase WBL activities across all programs to
include DW
Local Area Response: ESWC agrees DW funds did not meet the required threshold of 55%
established by CDLE however, we do believe there were mitigating circumstances which had an
impact. It should be noted ESWC successfully implemented SP-NEG in Weld County, and in
addition to expending 100% of initial allocation of SP-NEG funding before the end of the 4tn
quarter, ESWC intentionally did not co -enroll SP-NEG participants with Dislocated Worker under
WIOA. This deliberate strategy was designed to serve more individuals who were displaced,
ultimately supporting a higher volume of individuals served. Moreover, as a result of other local
areas not being able to enroll an adequate number of eligible participants which led to
insufficient expenditures statewide, Weld agreed to accept a second allocation of SP-NEG funds
to support statewide programmatic goals which took place in January 2017. At the time of
acceptance, USDOL had not responded to CDLE's request for a no -cost extension to continue SP-
NEG into PY17. Although Weld was eager to support statewide goals, it did impact our
expenditures in the Dislocated Worker program. Additionally, based on the uncertainty of
future funding for the PY 17 and FY 18 WIOA programs, the WCWDB and ESWC Leadership
discussed and determined that carrying out the maximum amount for funds in all programs
would help ensure stability. This strategy was taken to ensure existing program participants, as
well as new participants, were able to continue to receive services regardless of the
circumstances WIOA was facing.
It should be noted that expenditures during the first quarter of PY17 demonstrate ESWC's
independent accountability and call for action prior to the monitoring taking place. Taking into
consideration the increased SP-NEG allocations received mid -year as well as the increased
number of SP-NEG clients served, added to the immediate strategies implemented prior to
monitoring, ESWC requests CDLE consider reducing this finding to an Action Item. ESWC is
committed to working in partnership with CDLE to monitor expenditures throughout PY17 to
ensure all program funds are expended at the minimum threshold.
Employment Services of Weld County Annual Monitoring Report
Program Year 16
11 IPage
COLORADO
Department of
Labor and Employment
CDLE Response: CDLE accepts the response and acknowledges the mitigating factors. WDP
applauds the local area for stepping up to take additional grant dollars to serve Colorado job
seekers and employers.
CDLE will continue to review progress on the Technical Assistance plan monthly. CDLE is
encouraged by the local area's proactive approach to implementing strategies to achieve
spending goals, as evidenced by increased spending rates in the most recent quarter.
PGL ADM -2015-02 establishes an annual 70% expenditure goal for WIOA Title I programs, and
requires that spending at or below 55% be cited as a compliance issue. CDLE will review its
policy, and make necessary changes, to ensure it does not disincentivize local areas from
accepting additional grant dollars.
Section 4: Conclusion:
ESWC has a strong focus on providing quality customer -driven employment and training
services to the business community, job seekers, and other stakeholders. These services align
with the strategic objectives developed in collaboration with multiple partner programs within
the Northern Colorado community. The Weld 4 Works Youth Summer Employment Program
and the Work -Based Learning Cross Functional team are examples of the excellent service that
ESWC provides to its' job seekers and employers.
CDLE reviewed a total 148 participant files and job orders across the Adult, Dislocated Worker,
Youth, Wagner-Peyser, Trade Adjustment Act, Sector NEG, RESEA, and Hire for Colorado
programs, as well as program expenditures and participant data. The review resulted in one
compliance issue, one observation, and two recommendations.
CDLE fully recognizes the challenges caused by reduced funding in relation to providing quality
services. We are committed to working in partnership to support ESWC with its technical
assistance plan to address the issues identified in this report.
Please contact your Regional Liaison to coordinate any requested technical assistance.
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Employment Services of Weld County Annual Monitoring Report
Program Year 16
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