HomeMy WebLinkAbout20144001.tiff JOHN HICKENLOOPER oc•co4o DEPARTMENT OF LABOR AND EMPLOYMENT
Governor s.Afo
31 DIVISION OF EMPLOYMENT AND TRAINING
ELLEN GOLOMBEK .* ,* 633 17th Street, 7th Floor
Executive Director • #976 t Denver, Colorado 80202-3627
WILLIAM B. DOWLING
Director
ELISE LOWE-VAUGHN
Director Workforce Programs
December 24, 2014 RECEIVED
Sean P. Conway, Chair DEC 2 9 2014
Board of Weld County Commissioners
P.O. Box 758 WELD COUNTY
Greeley, CO 80632 COMMISSIONERS
Dear Mr. Conway:
The Colorado Department of Labor and Employment, Workforce Development Programs (WDP)
conducted the annual on-site compliance review of the Employment Services of Weld County
(ESWC) from September 8 to September 12, 2014. The review encompassed Workforce Investment
Act (WIA) programs, Wagner-Peyser, Employment Support Fund, Trade Adjustment Assistance Act
Program (TAA) and discretionary grants for the period September 1, 2013 through June 30, 2014.
The review was performed in accordance with CDLE Policy Guidance Letter# 08-18-WIA.
The executive summary and final report are enclosed. ESWC's responses have been incorporated
into the final report and a copy will be forwarded to the Chair of the Weld County Workforce
Investment Board (Dr. Mary Freitag) and the Division Head of the Employment Services of Weld
County (Linda Perez)
We would like to thank the staff of the Weld Workforce Region for the assistance they provided to the
State Workforce Monitors during all phases of the review. The staff was courteous and their
professionalism during the review was notable.
If you have any questions, please contact your Regional Liaison, Kelly Brown at 303.318.8016 or
kelly.brown anstate.co.us.
Sincerely,
Cr -�� -
Elise Lowe-Vaughn, Acting Director
Workforce Development Programs
COmm u -.wno
IZ 3i-rte/ CC N5bit -a ) 17 2014-1,100/
Colorado Department of Labor and Employment
Employment Services of Weld County
Program Year 2013 Annual Program Performance
Review
Final Report
Workforce Investment Act
Wagner-Peyser Act
Trade Adjustment Assistance
Discretionary Grants
Special Initiatives
Period of Performance:
September 1, 2013 — June 30, 2014
Kelly Brown
Regional Liaison
December 24, 2014
iish1/4
COLE COLORADO
Department of
CO Labor and Employment
Executive Summary
From September 8, 2014 to September 11, 2014, the Colorado Department of Labor&
Employment(CDLE) conducted an annual program performance review of all Workforce
Investment Act(WIA)Title I and Wagner-Peyser Act formula programs, the Trade Adjustment
Assistance(TAA) program, as well as discretionary grants, and special initiatives, operated by
Employment Services of Weld County(ESWC)from September 1, 2013 to June 30, 2014. The
review encompassed a 10-month time period that included Program Year 2013 (PY13).
Risk Assessment:
The Program Year 2013 (PY13)annual program review was augmented by the use of a Risk
Assessment instrument(PGL#08-18-WIA, Annual Compliance Monitoring and Risk
Assessment, Attachment 9, dated November 21, 2008).
ESWC is found to be at Low Risk in the GOVERNANCE, ADMINISTRATIVE,
PROGRAM/GRANT, AND FINANCIAL MANAGEMENT SYSTEMS, PROGRAM SERVICES,
DELIVERY SYSTEMS, AND DOCUMENTATION AND PERFORMANCE ACCOUNTABILITY
categories.
Promising Practices:
• ESWC has adopted a collaborative team approach across all programs to ensure
workforce center customers are aware of available program services ranging from
Wagner-Peyser workshops to WIA training opportunities. Throughout program year
2013 WIA staff members attended Emergency Unemployment Compensation (EUC)
orientations to share available WIA program services with customers. Information
sharing continues across agencies as workforce center staff members regularly attend
Temporary Assistance to Needy Families (TANF)orientations to inform TANF
customers of all workforce center services available to them.
• CDLE recognizes ESWC for their Career Pathways Partnerships. ESWC has an 80%
placement rate serving Out of School Youth populations, and shows the dedication that
ESWC has to the youth population.
• ESWC has a promising practice of providing each customer with very thorough
assessments. It is evident that these assessments are utilized throughout the
customers program to determine their skills, needs, progress and long term employment
goals.
• ESWC strategically leverages services of other programs. For instance, Disaster
National Emergency Grant(DNEG) participants also work with the Dislocated Worker
program in order to best serve the needs of the participant and assist him/her in
obtaining employment once his/her time with the DNEG program has ended.
Summary of Findings:
Action Items:
• One(1)common Action item associated with Adult, Dislocated Worker and H1-B Long-
Term Unemployed programs.
Recommendation/Observations:
• One (1) Dislocated Worker WIA Program
• One (1) Disaster National Emergency Grant(DNEG)
Employment Services of Weld County—PY13 Annual Compliance Page 1 of 6
Introduction
From September 8, 2014 to September 11, 2014, the Colorado Department of Labor &
Employment, Workforce Development Programs (CDLE/WDP), conducted an annual program
performance review of all Workforce Investment Act (WIA)Title I, Wagner-Peyser Act formula
programs, the Trade Adjustment Assistance (TAA) program, as well as discretionary grants
and special initiatives, operated by Employment Services of Weld County (ESWC)from
September 1, 2013 to June 30, 2014. The review encompassed a 10-month time period that
included Program Year 2013 (PY13).
An entrance conference was conducted on September 8, 2014; members of the CDLE/WDP
monitoring team and ESWC management team were in attendance. A subsequent exit
conference occurred on September 29, 2014, and was also attended by CDLE/WDP
monitoring staff and members of the ESWC management team.
A representative selection of case files was reviewed for all WIA formula programs, TAA,
discretionary grants, and special initiatives. In addition, a cumulative, year-end analysis of
participation, expenditures, and performance was completed for PY13. The review was
executed in accordance with COLE Policy Guidance Letter (PGL)#08-18-WIA, Annual
Compliance Monitoring and Risk Assessment Guidelines, dated December 10, 2008.
Definitions used in this report as specified by above PGL:
• 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 possibility of it
becoming a compliance finding.
• 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.
Promising Practices
Trade Adjustment Assistance (TAA). CDLE acknowledges that the majority of participants in
the TAA program at ESWC are successful in the completion of their chosen training plans.
TAA is a longer term program that can take two years or more for the customer to complete.
The ESWC counselors utilized other workforce center programs and quality assessments to
ensure their participants' financial and career pathway developed into a successful
employment outcome.
One example of this includes two different participants who were laid off in 2009 from a call
center and started their journey seeking a career plan for employment versus just another job
during the height of the recent recession. With the help of their counselor and their own
ambitions, they strived to give back to their community working on the flood related Disaster
National Emergency Grant (DNEG) in Weld County while continuing their educational
programs.
Employment Services of Weld County—PY13 Annual Compliance Page 2 of 6
One of those participants went to work for the United Way in a humanitarian flood related
position utilizing her skills and experience and was able to apply that experience into another
worksite helping other victims affected by the flood. During this time, the participant began
applying for employment to join Weld County after experiencing all of the positive assistance
provided to her in developing a career path. The other participant was also able to work for the
City of Evans in a humanitarian position related to the flood recovery. While there, she excelled
at the position and received accolades from her employer, and also state and Federal
personnel overseeing the program.
Amidst all of the flood related temporary employment, both participants resoundingly
completed their post educational degrees through the TAA program. Moreover, both
participants have since obtained full-time positions with the Weld County Department of
Human Services.
Risk Assessment
The PY13 annual compliance monitoring review was augmented by the use of a Risk
Assessment instrument(PGL#08-18-WIA, Annual Compliance Monitoring and Risk
Assessment, Attachment 9, dated November 21, 2008). Two categories of risk are utilized in
evaluating the workforce region.
• Low risk: First time compliance issues, limited deficiencies in program governance,
administration, delivery and accountability
• High risk: Inability to resolve compliance issues during the program year, major
deficiencies in program governance, administration, delivery and accountability
ESWC is found to be at Low Risk in the GOVERNANCE, ADMINISTRATIVE,
PROGRAM/GRANT, AND FINANCIAL MANAGEMENT SYSTEMS, PROGRAM SERVICES,
DELIVERY SYSTEMS, AND DOCUMENTATION AND PERFORMANCE ACCOUNTABILITY
categories.
Governance
Workforce Investment Board and Youth Council: The ESWC Workforce Investment Board
(WIB) is governed by the legal requirements of the Workforce Investment Act(WIA Sec 117;
WIA Final Rules 20 CFR, part 661, Subpart C. 661.300, dated August, 7, 1998). The
chairperson for the ESWC WIB must be a representative of the private business sector. In
addition, a majority of the members (51%) must represent businesses in the local area. The
ESWC WIB was found to be in compliance with membership requirements during the period
under review and met regularly and in accordance with legal requirements during the program
year.
The ESWC Youth Council exists under the authority of the ESWC WIB and the Workforce
Investment Ad(WIA)of 1998. THE ESWC Youth Council met regularly and in accordance
with legal requirements during the program year.
Memorandums of Understanding: Per WIA, Title I, Section 662.230 (c)—All required
partners must enter into a Memorandum of Understanding (MOU)with the local board relating
Employment Services of Weld County—PY13 Annual Compliance Page 3 of 6
to the operation of the One-Stop System that meets their requirements of 662.300, including a
description of services, how the cost of identified services and operating costs of the system
will be funded, and methods for referrals. The Monitors conducted a review of all required
Memorandums of Understanding (MOU) as part of the PY13 monitoring. All were found to be
up-to-date and in compliance.
One-Stop Operator Designation: ESWC continues to maintain its One-Stop Operator
certification as designated by the Colorado Workforce Development Council (CWDC). ESWC
has been recertified through June 30, 2016.
Local Planning: The annual plan for Program Year 2013 was submitted on time and
subsequently received unconditional approval from the CWDC.
Administrative, Program/Grant, and Financial Systems
Program/Grant Reporting Systems: ESWC continues to provide timely Quarterly Reports for
discretionary grants. Efforts in this area are a factor in the risk level being assessed as low for
the Administrative, Program/Grant, and Financial Systems category.
Internal and Subcontractor Monitoring: Internal monitoring and quality assurance for all
programs is effective at the ESWC. The internal monitoring process is well-conceived and
robust. This also contributed to the low risk level assessment in this category.
Administrative Policy Review: ESWC continuously reviews local policies for accuracy and
compliance with federal and local law. During the program review, two local policies were
identified as requiring updates. ESWC completed the updates immediately upon request and
have obtained WIB approval on both. CDLE appreciates the partnership with ESWC and the
swiftness at which ESWC completes and implements all recommendations.
Program Services, Delivery Systems, and Documentation
As part of the PY13 compliance monitoring review, the Monitoring Team conducted a
comprehensive review of a representative sample of WIA, TAA, and discretionary grant
records. In general, the files were in exceptional order, including required documentation and
adequate case notes, where applicable. Detailed monitoring logs have been made available to
the ESWC administrative team. The WDP monitoring team hereby cites the following action
items, recommendations and observations resulting from the case file reviews:
Action Item #1— Instances of errors during exiting procedures in the Adult, Dislocated
Worker and H1-B programs were cited. Seven (7)Adult, one (1) Dislocated Worker and five
(5) H1-B Long-Term Employed files presented with errors during the exit procedure. Common
examples noted were exiting a customer to employment without providing adequate case
notes to document the service that was provided, and Vocational Guidance services that do
not meet the definition of the service as stated in Connecting Colorado (Citation PGL 12-06-
WIA, dated June 6, 2012). Detailed case file review logs have been shared with the ESWC
Admin Team.
Although there are a moderate number of instances in which this error occurred, it has been
determined that these improper exits were completed by only a few staff members. ESWC
Employment Services of Weld County—PY13 Annual Compliance Page 4 of 6
expressed their desire to address this action item swiftly before it could adversely affect future
exits. The CDLE monitoring team provided technical assistance training on October 28, 2014
with ESWC staff representing all programs. ESWC has moved rapidly in correcting these
errors and receiving additional training. In the future, instances of errors in exiting procedures
may result in further action or compliance issues.
Region Response: Weld agrees with the citation in Action Item #1 — Instances of errors
during exiting procedures in the Adult, Dislocated Worker and H1-B programs. Technical
assistance has been provided onsite to ensure that all staff has clear guidance regarding exit
procedures.
CDLE Response: CDLE accepts this response.
Recommendation/Observation #1— One (1) Dislocated Worker participant file was
found to have an expired drivers' license. (Citation: PGL 12-06-WIA, dated June 6, 2012)
Detailed case file logs have been shared with the ESWC Admin Team. A current driver's
license was not in the file to support the issuance of transportation gas vouchers (none were
issued after the expiration). It is recommended/encouraged that internal quality control
develop a checklist or review process that will require the case manager or reviewer to review
expiration dates on Licenses, insurance cards and vehicle registrations to ensure that no
disallowed costs are incurred due to expired documentation.
Region Response: Weld acknowledges Recommendation/Observation #1 — One(1)
Dislocated Worker participant file was found to have an expired drivers' license. One file
having this issue over the course of the last several years does not indicate this is a pattern
and seems to be an oversight in an isolated scenario. File reviews are conducted to ensure
eligibility and compliance and this recommendation will be included in our quality control
process.
CDLE Response: CDLE accepts this response.
Recommendation/Observation #2:-Disaster National Emergency Grant- ESWC is
thorough in collecting eligibility documentation for all grant participants. It is recommended that
a case note is entered to further document and explain which eligibility reason; long term
unemployed, individual impacted by the floods, or dislocated worker was used to deem the
participant eligible for the program.
Region Response: Weld County's case notes are aligned with Recommendation/Observation
#2— Disaster National Emergency Grant. We agree that case notes within each NEG file
repeat the eligibility reason.
CDLE Response: CDLE accepts this response.
Performance Accountability
Grant Spending: At PY13 year-end, ESWC had met their formula funds spending
requirements in Adult and Youth programs at 82.63% and 70.17% respectively. Dislocated
Worker program spending was not met at 61.71%, for PY13 this is not a compliance issue;
Employment Services of Weld County—PY13 Annual Compliance Page 5 of 6
however, should underspending occur in PY14, it will result in a compliance issue. All expiring
funds were 100% spent (see Attachment#1).
Planned Program Activity: Actual participation in WIA Adult, Dislocated Worker and Youth
programs in PY13 met or exceeded the projections made as part of the Expenditure
Authorization plans. Actual participation was 123%, 98% and 110% respectively(see
Attachment#1).
Performance Measures: For PY13, ESWC met or exceeded all performance measures for
WIA and Wagner-Peyser(see Attachment#1).
Employment Services of Weld County—PY13 Annual Compliance Page 6 of 6
ATTACHMENT #1
Weld County WIA Adult PY13 Three Year At-A-Glance
Program ( PY13 End of Year) Last updated September 12, 2014
Colorado Activity Summary Report (data as of September 11 , 2014)
Program Year 2013
WIA Adult Performance Measures
Standard Actual Num/Den
Entered Employment Rate 75.70% 85.29% 116 / 136
Six Month Retention Rate 88.20% 84. 12% 143 / 170
Six Month Avg . Earnings $ 17,390.00 $ 15,463.67
Exceeded/ r10fOg tz / .:)W a -. /
Missed 1
Green = 100% or greater, Yellow = 99.99% - 90.00%. Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
PY13 performance and participants served is based on the most current PY13 Connecting
Colorado Activity Summary Report (data as of September 11 , 2014)
WIA Adult Participants Served Program Year 2013
Planned Actual Percent
Participant Carry-In 67 101 150.75%
New Participant Enrollments 152 169 111 . 18%
Total Participants Served 219 270 123.29%
Exceeded/ / ivi iv* / 3 0
Missed
Green = 100% or greater, Yellow = 99.99% - 90.00%, Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
PY13 end of year expenditures as of September 12, 2014.
WIA Adult Program Funding Program Year 2013
Previous PY Carry-in $ 180,767.77
PY/FY Allocation $803,336.00
Total Program Year Budget $984, 103. 77
Year to Date Expenditures $813, 118.30
Remaining $ 170, 985.47
Met or Exceeded/ / 82.637O
Underspent
Green = Expended 70% or more of progam funding, Yellow = 49.99% - 69.99% on target with expenditures
ATTACHMENT #1
Weld County WIA Dislocated PY13 Three Year At-A-Glance
Worker Program (PY13 End of Year) Last updated September 12, 2014
Colorado Activity Summary Report (data as of September 11 , 2014)
WIA DW Performance Measures Program Year 2013
Standard Actual Num/Den
Entered Employment Rate 78.90% 85.71 % 54 / 63
Six Month Retention Rate 88. 10% 91 .18% 62 / 68
Six Month Avg . Earnings $ 19,733.00 $ 16,985.37
Exceeded/ 1s / :cw Me /
Missed 2
Green = 100% or greater, Yellow = 99.99% - 90.00%, Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
9 g g
PY13 performance and participants served is based on the most current PY13 Connecting
Colorado Activity Summary Report (data as of September 11 , 2014)
Program Year 2013
WIA DW Participants Served
Planned Actual Percent
Participant Carry-In 53 64 120.75%
New Participant Enrollments 65 52 80.00%
si
Total Participants Served 118 116
e
Exceeded/ / ow ,, / 1 0
Missed
Green = 100% or greater, Yellow = 99.99% - 90.00%, Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
PY13 end of year expenditures as of September 12, 2014.
WIA DW Program Funding Program Year 2013
Previous PY Carry-in $249,206.68
PY/FY Allocation $244,619.00
Total Program Year Budget $493,825.68
Year to Date Expenditures $304,759.39
Remaining $ 189, 066.29
Met or Exceeded/ /
Underspent
Green = Expended 70% or more of progam funding, Yellow = 49.99% - 69.99% on target with expenditures
ATTACHMENT #1
Weld County WIA Youth PY13 Three Year At-A-Glance
Program ( PY13 End Of Year) Last updated September 12, 2014
Colorado Activity Summary Report (data as of September 11 , 2014)
Program Year 2013
WIA Youth Performance Measures Standard Actual Num/Den
Literacy/Numeracy 48.00% 55. 10% 54 / 98
Education Placement 66 .70% 69.07% 67 / 97
Degree/Cerificate 69 .00% 73.04% 84 / 115
W Exceeded/ 3 0
Missed
Green = 100% or greater, Yellow = 99.99% - 90.00%, Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
I
PY13 performance and participants served is based on the most current PY13 Connecting
Colorado Activity Summary Report (data as of September 11 , 2014)
Program Year 2013
WIA Youth Participants Served
Planned Actual Percent
Participant Carry-In 129 113 87.60%
New Participant Enrollments 82 119 145. 12%
Total Participants Served 211 232 109.95%
Exceeded/ / Me /
Missed 2 '
Green = 100% or greater, Yellow = 99.99% - 90.00%, Orange = 89.99% - 80.00, Red = 79.99% or below negotiated levels.
PY13 end of year expenditures as of September 12, 2014.
WIA Youth Program Funding Program Year 2013
Previous PY Carry-in $286, 718.32
PY/FY Allocation $687, 164.00
Total Program Year Budget $973,882.32
Year to Date Expenditures $683,333.47
Remaining $290,548.85
Met or Exceeded/ /
Underspent 70. 17%
Green = Expended 70% or more of progam funding, Yellow = 49.99% - 69.99% on target with expenditures
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