WIOA Monitoring: Updates and PY 2017 Preparation

Presentation Format

Presentation Agenda

OVERVIEW OF PY2016

2%13%

80%

5%

PY16 Results

Technical Assistance

Recommendations

Required Follow Up

Findings

Missing Providers

Case Notes

Scanning and Redaction

Internal Monitoring

Updates to Board Policy

Updates to IEP/ISS

File Review Updates and Corrections

18%

47%

35%

PY 2016 RESULTS

Findings Observations Recommendations

FINANCIAL OVERVIEW OF PY 2016

• No sample checklist will be provided prior to monitoring

• Decrease time of monitoring visit or allow for a more comprehensive visit (speak to contractors, visit career centers, etc.)

• If something is “missing” from electronic file, it will automatically go into the summary report

• Make sure ALL verifications and case notes are uploaded online and correctly labeled

If an issue was documented as

needing a required follow-up in

the previous program year and is

still considered an issue in the

current program year

“This will be an automatic finding”.

• One code will be used for both adults and youth (CSS).

• A case note will be entered and should contain specific

information on the type of support service, duration, and

the provider.

• It is suggested that staff input a CSS activity with a

projected ending date as a reminder to invoice this

service.

• Once the invoice is received, the actual start and

end date can be updated to reflect the date of

invoice.

• Youth Objective Assessment (412) and Youth Creation

of IEP/ISS (413) do not trigger enrollment.

• NCWorks will require that when creating

a Participation (enrollment), (417)

Comprehensive Guidance and

Counseling must be entered first,

followed by 412 then 413.

Questions from Around the State

Is there a specific way that documents should be

labeled and uploaded into NCWorks Online? Is it

acceptable to upload attendance sheets in one

document for the semester and identify the months or

upload separately for each month?

At the moment, there is no specific guidance on

how documents should be named. It is highly

recommended that documents be named as

to what the document is, and that documents

are scanned individually.

What documentation is needed to verify Long-term

Unemployment? Does long-term unemployment include

individuals that are unemployed, receiving social security disability

payments, but looking for employment? If an individual has retired

and now wants to enroll in training to obtain employment in a new

field, are they long-term unemployed?

In PS 02-17, long-term unemployment is defined by the State of NC as 13 or

more consecutive weeks of total unemployment. Wage records, manually

checking mainframe, or Self-Attestation are examples used to verify the 13

or more weeks of total unemployment.

An unemployed individual receiving SSDI would still be required to meet all

eligibility requirements as any other Dislocated Worker. More info should be

gathered (type of disability, type of training they are wanting to obtain,

etc) to ensure correctness of program. If an individual has retired and is

looking to obtain training to re-enter the workforce, they will be enrolled as

an Adult, because they made the decision to retire on their own behalf.

If a local area’s supportive service policy does not cover

items such as stethoscopes, tools, uniforms, etc. are we

required to create a supportive service activity for those

purchases by individuals enrolled in training which

require those items? Will you be required to include these

items on an ITA?

If a WDB has an internal policy stating what will not be covered for an individuals training, it is not necessary to create a supportive service for the purchase of those items, document the items in a case note, or record those items on an ITA.

If items are in the hard file and not uploaded into

NCWorks Online, will the Local Area be given an

opportunity to upload the information before the

monitoring report is written? Will this be a Finding

requiring corrective action?

For PY 2017 this will be a potential finding. When Policy Statement 08-17 was issued, the decision to perform Case File Reviews at the monitor’s desk was made. It is crucial that ALL case files are scanned, all eligibility/supporting documents are included, and supporting case notes are entered.

How do you document Selective Service for Transgender

individuals? If you have a transgender female that identifies as a

male, what documentation will you need to get around the

Selective Service and how would you answer this question in

NCWorks?

Those identifying as males who were females at birth are not required to register. However, the SSS requires those individuals identifying as females who were born male to register with the system.

1) When possible, other data verification documents (like a birth certificate) can satisfy the question of one’s compliance with the SSS. Be mindful these other documents cannot simply be ‘required’ for program eligibility to avoid this specific situation.

2) When this is not convenient, the individual can contact the SSS Registration Information Office by phone (1-888-655-1825).

3) If neither of the above is possible, the individual could request that the WDB make a determination whether the individual knowingly or willfully did not register with the SSS – using existing policy and established guidelines.

In any case, staff may need to select “Did not self-identify” for the Gender field within NCWorks Online in order for the Registered for the Selective Service dropdown options NOT to default to “Not applicable” .

This will allow staff the flexibility to make a more appropriate choice from the dropdown (see screenshot below) when the individual is NOT required to register based on their gender at birth, but currently identify as a male.

How will using NCWorks Online affect the on-site

monitoring process? What are the significant

changes?

With monitors completing the Case File review at their desks, this may shorten the overall monitoring visit.

As long as the WDB’s are scanning and documenting case notes appropriately, the impact of this process will be minimal.

Policy Statement for

Financial Management

Revisions

TABLE OF CONTENTS

North Carolina Division of Workforce Solutions

Financial Management Policy

For Workforce Innovation and Opportunity Act funds

TABLE OF CONTENTS

VII. Property Procedures 5

A. Equipment and Property Management 5

B. Auditable Areas 6

C. Acquisition 6

D. Lease of Equipment 7

E. Computer Equipment 7

F. Missing, Stolen, or Maliciously Damaged Property 7

VIII. Consultants and Personal Service 8

North Carolina Division of Workforce Solutions

Financial Management Policy

For Workforce Innovation and Opportunity Act funds

TABLE OF CONTENTS

VII. Property Procedures 5A. Equipment and Property Management 5B. Auditable Areas 6C. Acquisition 6D. Lease of Equipment 7E. Computer Equipment 7F. Missing, Stolen, or Maliciously Damaged Property 7

G. Disposition of Property 8

VIII. Consultants and Personal Service 9

IX. Outreach Services 9

Prior Revised

VII. C. ACQUISITION

All property with unit costs of $5,000 or more or an aggregatepurchase (a purchase of multiple items of the same product) is $5,000or more (taxes, shipping and handling costs included) must have DWSwritten certification that the Local Area is in compliance withapplicable State and Federal laws and regulations, and, arenecessary and reasonable. All purchase requests must be submittedto the assigned DWS Field Services Financial Monitor andaccompanied by the following documentation:

All property with unit costs of $5,000 or more or an aggregate

purchase (a purchase of multiple items of the same product) is

$5,000 or more (taxes, shipping and handling costs included)

must have DWS written certification that the Local Area is in

compliance with applicable State and Federal laws and

regulations, and, are necessary and reasonable. All purchase

requests must be submitted to the assigned DWS Financial

Monitor and accompanied by the following documentation:

Prior Revised

Not Addressed Equipment items with a current per unit fair market value of less than $5,000may be retained, sold or disposed of with no obligation to the North Carolina

Division of Workforce Solutions.

For equipment with a fair market value of $5,000 or more, recipients of WIOAfunds should take the following steps with reference to[2 CFR 200.313 (5) (e) (1) (2) (3) (4), 29 CFR 97.32 (g) and 29 CFR 95.34 (c )] :

VII. G. DISPOSITION OF PROPERTY

Prior Revised

Not Addressed. 1. The recipient may use the equipment in the program or project for which itwas acquired as long as needed, whether or not the project or program continues to be supported by federal funds.

2. If the equipment is no longer needed by the original program/project, therecipient shall use the equipment in connection with its other federallysponsored activities. Priority should be given to programs funded by theDOL Employment Training Administration.

3. If the equipment is no longer needed by the program/project or used inconnection with other federally sponsored activities, the recipient may:

a. Retain the equipment for other usesb. Transfer the title to a third party orc. Sell the equipmentIf the equipment is retained, transferred or sold, then compensation must bemade for the WIOA federal funds used in the purchase. The amount of compensation shall be computed by applying the percentage of WIOA federalfunds used in the purchase. If only WIOA federal funds were used for the purchase then the percentage would be 100 percent. If both WIOA federaland local funds were used in the purchase then use the WIOA federal fundspercentage for the calculation. This percentage is applied to the fair market value or proceeds of the sale for the equipment. Recipients of sub grants arepermitted to deduct actual reasonable selling and handling expenses($500 or 10 percent of the proceeds of the sale, whichever is less) from theproceeds of the sale. The balance of WIOA federal funds must be sent within30 days to the DWS Finance Unit. The Name of the Entity, Agreement Number, Program Year and Funding Stream must be provided when submitting the funds.

Prior Revised

VII. G. DISPOSITION OF PROPERTY CON’T.

Not Addressed. 4. In the case of retention, transfer or sale of the equipment, a Request forTransfer or Disposition of Excess Property should be submitted and

communicated to the DWS for pre-approval. All such forms, yearly inventory reports and requests for disposition approvals must be submitted to therespective DWS Grant Administrator at the Division of Workforce Solutions

5. Computation of "Fair Market" Value: The selling price of an item that is soldthrough auction, advertisement, or a dealer is the fair market value of the item regardless of any prior estimates. An item that is not sold but retained by the entityhas a fair market value based on similar items that are offered for sale, using theselling price if known. Methods for determining fair market value include, but are not limited to: Auction, Classified advertisements for similar used item, Dealers and

Licensed appraisers. (For automobiles, trucks, and vans, the standard authority on thevalue of used vehicles is the Kelley’s Blue Book).

Property Records Retention: Property records (for all WIOA property items costing$500 and above) must be maintained from the date of acquisition, through final

disposition. Sub recipients must also retain those records for a period of three years from the date of their last expenditure report submitted to the DWS. If any litigation,claim, or audit is started before the expiration of the three-year period, all records mustbe retained until all findings have been resolved and final action taken.

Prior Revised

VII. G. DISPOSITION OF PROPERTY, CON’T

For the purchases of personal services of consultants when the deliverables

are specifically defined and priced. Consultants and personal services

contracts, costing $5,000 and over, must be filed with the DWS Field

Services Fiscal Monitor before the contract is finalized. The filing is to be

submitted to DWS a minimum of ten (10) business days prior to execution of

contract. During the onsite monitoring, the DWS Field Services Monitor will

review the contract documentation against the filing submitted to DWS. The

filing submitted to the Division must include:

1. The cost of the proposed contract;

2. The starting and ending dates;

3. The purpose of the contract;

4. List whether the procurement is Competitive or Non-Competitive; and

5. The funding source to be used.

VIII. CONSULTANTS AND PERSONAL SERVICE

RevisedPriorConsultants and personal services contract, costing $5,000 and

over, must have DWS review and written compliance certification

before the contract is finalized. Requests are to be submitted to

the assigned DWS Field Services Financial Monitor.

As a minimum, the letter to DWS requesting review and written

compliance certification must contain the following information:

1. The cost of the proposed contract;

2. The starting and ending dates;

3. The purpose of the contract;

4. The assurance of adherence to local and state procurement policies; and

5. The funding source to be used.

Not Addressed. Pursuant to the Uniform Administrative Guidance WIOA 2 CFR 200.421 (b)(4),WDBs may purchase outreach materials to promote WIOA services and programs to eligible audiences. The material must be necessary, reasonable,allowable and allocable and at a minimum the documentation must include the following:

1. The material must contain information related to the WIOA program.2. The WDB’s Plan/Statement of Work (SOW) must detail the events for which the

outreach materials will be provided.3. Detail the measures for safeguarding the outreach materials.4. Three quotes are required for procurement regardless of cost.5. List the funding source to be used.

IX. OUTREACH SERVICES

Prior Revised

§200.403 Factors

affecting allowability of

costs.

§200.404 Reasonable

costs.

§200.405 Allocable

costs.

Procurement and

Contracting Policy

1. MICRO-PURCHASE OPTION

Not Addressed.Micro-Purchase Option – Threshold: $0 - $2,500. An acquisition of products or services where the aggregate amount does not exceed $2,500. An exception to the formal procurement method is the case of purchases less than or equal to $2,500 (i.e., micro purchases) or other lower threshold set by WDBs as they deem appropriate for purchases in their policies. Purchases below that threshold may be made without soliciting competitive price or rate quotations if the price is considered to be reasonable. A reasonable price may be by comparing to a previous purchase, personal knowledge of the item being purchased, or by comparing to similar items being purchased. Records still need to be kept for all purchases regardless of the procurement method used, including micro-purchases. Also, to the extent practicable, micro-purchases must be distributed equitably among qualified suppliers.

Prior Revised

2. SMALL PURCHASE

OPTION

Small Purchase Option. A simple and informal competitive process for securing services, supplies and other property that do not cost more than $5,000 in the aggregate on an annual basis is allowable. For purposes of economy, responsiveness to needs and administrative efficiency, the WDB may consolidate procurements for similar needs (e.g., yearly requirements for office consumables or instructional materials), or break out project requirements into more than one procurement (e.g., separating computer hardware and software) in order to procure the best and most effective items in each category.

This option may not be used to purchase training services.

The WDB must not break out purchase requirements for the sole purpose of staying under the aggregate limit of $5,000 or the administrative entity’s limit, if lower. The following requirements must be met and documented:

Small Purchase Option $2,501 - $$5,000. A simple and informal competitive process for securing services, supplies and other property that do not cost more than $5,000 in the aggregate on an annual basis is allowable. For purposes of economy, responsiveness to needs and administrative efficiency, the WDB may consolidate procurements for similar needs (e.g., yearly requirements for office consumables or instructional materials), or break out project requirements into more than one procurement (e.g., separating computer hardware and software) in order to procure the best and most effective items in each category.

This option may not be used to purchase training services.

The WDB must not break out purchase requirements for the sole purpose of staying under the aggregate limit of $5,000 or the administrative entity’s limit, if lower. The following requirements must be met and documented:

Prior Revised

3. AGGREGATE PURCHASE

Not Addressed.

Aggregate Purchase. A purchase of multiple items of the same product.The aggregate purchase costing $5,000 and over, must be filed with theDWS Field Services Fiscal Monitor before the purchase is completed. Thefiling is to be submitted to th DWS a minimum of ten (10) business days priorto purchase. During the onsite monitoring, the DWS Field Services Monitorwill review the purchase documentation against the filing submitted toDWS.

Prior Revised

2. EMERGENCY

Emergency. The use of sole sourcing for emergency situations should be infrequent and for limited time periods (i.e., reflecting the emergency). If the need generated by the emergency will continue over an extended period of time, a competitive procurement method must be used after the emergency has been resolved.

Emergency. An emergency situation is one that endangers lives, property, or causes the immediate discontinuation of a vital program and which can be rectified only by immediate on-the spot purchase (or rental) of equipment, supplies, materials, printing, or contractual services. In an occurrence of this nature, where the cost exceeds the micro-purchase limit ($2,500) the WDB should contact their assigned DWS Financial Monitor via email as soon as possible; noting the specific emergency and what measures are being taken to rectify the situation.

The WDB should negotiate with a potential vendor(s) in an effort to acquire the quality of good or service needed at the best possible price, delivery, terms and conditions. A solicitation document requesting or inviting an offer(s) shall be issued, including standard language terms and conditions unless circumstances prohibit their use.

Subsequently, whether or not such prior approval was possible, if the expenditure is over the WDB’s micro-purchase limit, an explanation of the emergency purchase shall be reported in writing to the DWS Financial Monitor. If under the WDB’s micro-purchase limit, documentation shall be included in the WDB’s procurement file.

The use of sole sourcing for emergency situations should be infrequent and for limited time periods (i.e., reflecting the emergency). If the need generated by the emergency will continue over an extended period of time, a competitive procurement method must be used after the emergency has been resolved.

Prior Revised