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Home My WebLink About20140086.tiff JOHN HICKENLOOPER oe coo DEPARTMENT OF LABOR AND EMPLOYMENT Governor i� �9a of DIVISION OF EMPLOYMENT AND TRAINING ELLEN GOLOMBEK '** �_�� 633 17'"Street,7`h Floor Executive Director "1a7s% Denver, Colorado 80202-3627 WILLIAM B. DOWLING Employment&Training Director ELISE LOWE-VAUGHN Workforce Programs, Policy and (� Strategic Initiatives Director A`cg Ec January 3, 2014 JAN -.6 ,5O1, Sean P. Conway, Chair C ,L co Sean Board of Weld County Commissioners ,s PO Box 758 Greeley, CO 80632 Dear Mr. Conway: The Colorado Department of Labor and Employment (CDLE), Workforce Development Programs (WDP) conducted the annual on-site compliance review of the Employment Services of Weld County (ESWC) from September 23 to September 26, 2013. 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 July 1, 2012 through August 31, 2013. 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 also be forwarded to the Division Head of the Employment Services of Weld County (Linda Perez) and the Chair of the Weld County Workforce Investment Board (Dr. Mary Freitag). 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(a)state.co.us. Sincerely, Elise Lowe-Vaughn, Policy and Strategic Initiatives Director Workforce Development Programs Cc: Celia Hardin, Supervisor, Workforce Development Programs Keith McNeal, CDLE Auditor 2014-0086 Yl�u LtF,4lr Z?N X512 ( r/o'/c� CM/ � a©- RD/ ► !1171 (4 Program Year 2012 Annual Compliance Monitoring Final Report Employment Services of Weld County Workforce Investment Act Wagner-Peyser Special Initiatives, Discretionary Grants and Trade Adjustment Assistance Act Period of Review July 1 , 2012 through August 31 , 2013 December 2013 Prepared by Kelly Brown Workforce Development Programs Colorado Department of Labor and Employment Workforce Development Programs EXECUTIVE SUMMARY From September 23 through September 26, 2013, the Colorado Department of Labor and Employment (CDLE) conducted an annual compliance review of the Employment Services of Weld County (ESWC). Program monitors reviewed the areas of governance, administration, program and service delivery systems as they relate to the Workforce Investment Act (WIA) Title I and Wagner-Peyser Act. Monitors also reviewed Special Initiatives, Discretionary Grants and Trade Adjustment Assistance Act (TAA) for the ESWC. Acknowledgements, compliance findings and risk assessment found in the review are summarized below. Region Recognition and Acknowledgements: • Veteran's Preference-Veteran customers are acknowledged immediately with posters/signage on the walls and countertops. There is a designated customer service representative specifically for Veterans. • Language Assistance Posters are easily identified within the resource room. If there is an immediate need for interpretations services, customer service representatives are resourced with a telephone number where an interpreter is available to assist telephonically. • CDLE commends the ESWC for meeting six of the negotiated statewide common measures at 100% and the remaining three at 80-99%. This is an outstanding accomplishment. Compliance Findings and Action Items: • No compliance issues were identified during the period of performance under this review. • Seven (7) action items were identified in the WIA program. Risk Assessment: • Based on the findings in this review, ESWC is determined to fall in the low risk category. 2 Introduction and Methodology From September 23 through September 26, 2013, state workforce program monitors with the Colorado Department of Labor and Employment (CDLE) conducted an onsite compliance monitoring review of the workforce programs operated by the ESWC for the Program Year 2012 (PY12), encompassing the date range of July 1, 2012 through August 31,2013. This comprehensive review included the following programs: Workforce Investment Act (WIA)Adult, Dislocated Worker, and Youth Programs; Wagner-Peyser (WP); Special Initiatives; Discretionary Grants; and the Trade Adjustment Assistance Act (TAA). This review was conducted in accordance with CDLE Policy Guidance Letter(PGL)#08-18-WIA, which includes as attachments all the monitoring instruments used throughout the review. Employment Services of Weld County is the official name for this workforce region. For purposes of the report, they will be referred to as the ESWC. Prior to onsite monitoring, an entrance interview was conducted on September 23, 2013, with CDLE program monitors led by Petra Chavez and the management team from ESWC. An exit interview detailing the findings of compliance monitoring was conducted on October 17, 2013, with the management team from ESWC: Linda Perez, Ted Long, Tami Grant, Rene Gonzales, Ann Stelling, and Heather Kreeger. CDLE staff present at the exit included Petra Chavez and Kelly Brown. The annual compliance monitoring process evaluates key categories in order to systematically identify areas of success, as well as those in need of improvement. Monitoring and risk assessment can identify deficiencies and trends, and may result in targeted training and technical assistance. A. Case File Reviews A random case file sample is generated at CDLE for each of the programs operated in the region. This file sample was sent to the region seven (7) calendar days before the beginning of the monitoring. WIA and TAA Programs random sampling included: • Dislocated Worker 19 files • Adult 19 files • Youth 15 files • TAA 11 files Wagner-Peyser Program random sampling included: • Wagner-Peyser Participant Files 30 files Special Initiatives random sampling included: • SECTORS Initiative 5 files • Emergency Unemployment Compensation (EUC) 5 files • H-1 B Technical Skills Grant 9 files • Unemployment Insurance Pilot Project 5 files B. Risk Assessment Annual compliance monitoring is conducted with a view towards assessing risk in four key categories: 1) Governance 3 2)Administration, Program and Financial Systems (includes but is not limited to program reporting system, local policies and procedures, internal controls and internal monitoring) 3) Program Services, Delivery and Documentation 4) Performance Accountability CDLE's monitoring approach is outlined in detail in PGL#08-18-WIA, and identifies two categorizations of risk, low and high. A rating of low risk generally indicates first-time areas of concern or warning. A rating of high risk indicates larger systemic gaps, repeat areas of concern or warning, and a discernible pattern of shortcomings in one or more areas. Because the overarching categories encompass many parts, sub-categories are utilized to provide a targeted analysis, and clearer identification of risk. Categories where the region is found to be performing well and in compliance with Federal, State and local requirements are deemed to be no-risk. RESOLUTION OF PREVIOUS YEAR COMPLIANCE FINDINGS AND RISK ASSESSMENT Program Year 2011 (PY11) Compliance Findings There were no compliance findings identified by program monitors during the PY11 review. Risk Assessment Based on the findings in this review, ESWC is found to be low risk. PY12 MONITORING RESULTS A. Definition of Compliance Finding, Action Item, and Recommendation: • A compliance finding is a violation against legal or policy requirements considered to be a more prevalent problem than an individual exception to the rule. Compliance issues must be corrected (if possible)to avoid any potential repercussions or corrective actions. • An action item is a specific request to make a correction to avoid the possibility of it becoming a compliance finding in the future. • A recommendation addresses an issue where there is currently no compliance finding, but a recommendation is made to improve or enhance a program or system's processes or outcomes. A workforce region is not required to implement recommendations made in the report. B. Compliance Findings and Action Items Governance No compliance issues or action items identified. Administrative, Program/Grant, and Financial Management Systems Policies: 1 Action Item • The monitors found one policy that was out of compliance at the time of the review. ESWC policies currently out of compliance: Job Central Job Orders— ESWC has been uploading job orders from Job Central (a state-approved outside entity that posts job openings) since October 2012. Per PGL 12-11-WP (III)(C)(4), Guidelines Regarding Job Orders and Business Services, dated 4 December 5, 2012: Workforce centers should have policy and procedure guidelines to determine how an employer becomes "Trusted."A "Trusted"employer is one that has been determined to meet all the guidelines of an approved job order and be deemed to not need verification. Local policy will additionally outline processes "to un-trust" an employer in the event job orders become compromised. (p. 14) Without this policy in place, ESWC lacks guidelines and processes on handling Job Central job postings and there is no consistency. At the time of this report, ESWC has been uploading job orders from Job Central for approximately 12 months. Required Action: ESWC needs to revise the local Job Order policy for the items outlined above, and submit it to CDLE no later than December 31, 2013. Region Response: ESWC agrees with this finding and understands the need to include policies and procedures regarding how an employer becomes"Trusted"or"Un-Trusted". The written policy has been adjusted to reflect this change in the PGL and the related excerpt of the revised policy is included as a separate attachment with this response. CDLE Response: CDLE has reviewed the modification to the policy that Weld submitted and approves of the modification. Please note that modifications to policies must be reviewed and submitted to LWIB for approval. The effective date of the policy is the date of the WIB approval. Program Services, Delivery Systems and Documentation Dislocated Worker: 3 Action Items • Three (3)files reviewed presented program exit dates that did not have corroborating services. PGL 12-06-WIA, dated June 6, 2012; Section IV.A states that ". . . . Program performance measures are keyed to the participation cycle, therefore, accurate documentation and data entry of enrollment and exit dates, as well as reportable services and follow-up services into the Connecting Colorado database, are critical". Required Action: The local monitoring or management team will need to provide training and, or clarification on proper WIA exit procedures. PGL 12-06-WIA; Section IV. A. 4; Exit and Extending Enrollment. • Vocational Guidance (VG) service was used as an exit service in seven (7) files reviewed. In each instance the qualifying definition for VG is not applied. Based on the monitors review, it appears that vocational guidance may not have been the correct code to reflect the actual service that occurred. Case notes in the file were vague and although it looked as if there may have been a service to the participant, it appears that the VG may also have been used as an administrative marker. Required Action: The ESWC case management team should identify, based on definition, how to appropriately use the VG service. ESWC with the assistance of the monitoring team will need to provide training to case managers on the proper manner in which to use the VG service and insure that case notes are detailing the actual service more thoroughly. This information can be obtained by reviewing the Data Integrity Program Guidance Letter. PGL 12-06-WIA;specifically, Section IV.3; Service Provision. 5 • Three (3) files reviewed presented data integrity issues with the Occupation Training (OC) service code. Two (2) files did not match the vendor training schedule start date and one (1) file did not have the OC service entered into Connecting Colorado yet there is a case note and vendor documentation identifying training dates. Action: of the training begin dates to be in accordance with what th e Required Revision g training schedule identified. PGL 12-06-WIA; Guidance on Data Integrity and the Customer Participation Cycle for WIA and TAA Programs. Region Response: (1) ESWC agrees with this finding and will take measures to ensure that staff members receive re-training on proper exit procedures including exit date reporting. (2) ESWC partially agrees with this action item. The use of the Vocational Guidance(VG) service code within these files reflects an actual service provided to clients. ESWC acknowledges that VG, as a marker service, is not appropriate and ESWC managers will direct staff to provide more detailed case notes on the VG services provided when the code is used in the future. (3)ESWC agrees with this finding and will take action to ensure that the OC service code of every file is entered into Connecting Colorado and matches the vendor training schedule start date. CDLE Response: CDLE accepts response. CDLE understands that the VG services noted during the PY12 monitoring reflected actual services, adequate documentation of these services will reduce or eliminate future action or compliance items. WIA Youth: 1 Action Item • Five (5) out of 15 files reviewed included an incentive award that was not established as part of the participant's Individual Service Strategy (ISS). Per PGL 10-03-WIA, dated March 2, 2010, incentive payments must be tied to ISS goals. Furthermore, the establishment of incentive opportunities prior to goal attainment must be consistently documented in order to avoid the appearance of awarding a "bonus". Required Action: It is strongly recommended that incentives be included in the ISS for all participants for which they are appropriate, based on assessment and local policy. Doing so will ensure these payments are clearly benefiting the program. Documenting incentives in the ISS will mitigate further concerns and/or future compliance issues when providing strategies to achieve youth goals, particularly goals tied to an incentive. For further Individual Service Strategies (ISS) guidance and case management practice provisions refer to TEGL 33-12. Region Response: ESWC currently emphasizes to participants the relationship between incentives and the ISS, but agrees to formalize these incentives as part the ISS for all participants. WIA Youth staff will continue to clearly communicate the instrumentality of ISS goal attainment in receiving incentives. CDLE Response: CDLE accepts response. 6 Trade Act Adiustment Act (TAA) - 1 Recommendation The TAA orientation presentation contains out of date information from expired TAA laws. Recommendation: Apply the recommendations provided during the technical assistance provided by TAA staff to ensure that information contained in the orientation presentation is reflective of the current TAA laws and regulations. Note: The suggested revisions were been made to the orientation presentation immediately upon the technical assistance provided to ESWC by TAA staff. Region Response: The suggested revisions were made to the orientation presentation immediately upon the technical assistance provided to ESWC by TAA staff. CDLE Response: CDLE accepts response. There are new TAA laws taking effect in 2014, CDLE strongly suggests that ESWC TAA staff work closely with CDLE TAA staff to review all new laws in order to keep the orientation presentation current and reflective of all laws and regulations. Performance Accountability Performance Goals: 1 Recommendation ESWC did not meet the performance goal for planned participation in the Dislocated Worker program for PY12. ESWC submitted an Expenditure Authorization (EA) Modification during the final months of PY12, which identified a planned increase in the participation count to 180 participants. Final PY12 Performance actuals for ESWC is 132 participants; this is 73.33% of 180 (planned) or 15% less than the performance goal. Required Action: ESWC must insure that local performance monitoring procedures are continued and/or augmented. When considering a modification to planned performance in the final months of the performance year, ESWC is encouraged to work with their regional liaison and monitoring team to insure that increases or decreases in performance are based upon data in order to avoid possible compliance issues in the future. Region Response: ESWC's planned participation for the PY12 Dislocated Worker program was adjusted to 180 in anticipation of a notice by the State of eligible individuals through the Ul Pilot program but ultimately no eligible individuals were found in the system within ESWC's service area. ESWC agrees to make every effort to base planned participation on sound information and modify as needed to ensure participation goals are met or exceeded. CDLE Response: CDLE accepts response. CDLE regional liaison and monitoring team will continue to work with ESWC to ensure that all EA modifications are in the best interest of the region. 7 Statewide Common Measures: ESWC met or exceed all Statewide Common Measures for PY12. u11 'Statewide Commen Measures WIA PY12: 4th Quarter r s;.,A` (green = 100% of neg. level) (blue=80-99% of neg. level) (red = below 80% of neg. level) Weld Standards Statewide Standards }^ia� ii i la i �^iRl 43 r'I l ^ Adult Measures ,r., Entered Employment Rate 86.41% 76.00% 77.56% 76.0% Six Month Retention Rate 88.97% 86.00% 86.49% 86.0% Six Month Average Earnings $16,259.32 $17,500.00 $16,778.97 $17,000.00 Rislocateci Worker Y `' Entered Employment Rate 85.90% 80.00% 81.72% 80.0% Six Month Retention Rate 91.67% 87.00% 89.56% j 87.0% Six Month Average Earnings $14,090.35 $16,750.00 $19,575.78 $21,500.00 ;NXS)Ut�11 Measp'I�eS+l'�iiA±l��i�t'.jl I Degree/Certificate 69.80% 70.91% 70.82% 69.0% Literacy/Numeracy 62.35% i 55.59% 48.01% 49.0% Education Placement 71.13% I 68.00% 68.18% 68.0% Tir !Exceeded/M / etIVII≥sedtio°ealli1 6 -3 -0 6 -3 - 0 'Statewide'Common",Measures-.Wa•ner<Pe ser PY12 4th,Quarter Weld Statewide Standards MesSuresSOl r au6OO tDii=1' Entered Employment Rate 54.96% 53.26% 50.0% Six Month Retention Rate 76.28% 75.89% 77.0% Six Month Average Earnings $14,921.00 $15,197.00 $15,000.00 i'Exceeded/MetlMissed','Goalyi� 1 -2 -0 2 -1 - 0 8 Acknowledgements: CDLE would like to recognize the following accomplishments of ESWC: CDLE recognizes and commends ESWC for maximizing resources to continuously serve a larger number of participants. ESWC shows a constant commitment to their local community by leveraging resources to help as many residents as possible. ESWC's Workforce Investment Board (WIB) meets all membership requirements. Local boards are essential to the success and strategic direction of a workforce region. ESWC has been proactive in the continuous monitoring and constant recruitment of the local WIB. In September 2013, Weld County experienced catastrophic floods unlike any other in recent history. ESWC assisted the Weld County Emergency Operation center in the early days after the flooding. ESWC worked with the Weld County Emergency Response Team and various other agencies to provide shelter, road closure information, evacuation and other vital assistance to those hardest hit. ESWC has demonstrated exemplary customer service while providing assistance to individuals negatively impacted by this natural disaster. CDLE commends the efforts of ESWC for their efforts in the early days following this disaster, and their continued efforts with the Disaster National Emergency Grant (temporary jobs) to assist their local community during this unprecedented disaster recovery. 9 Hello