Monitoring of WIOA Programs Interim Policy & Procedures

Transcription

1 POLICIES & PROCEDURES Monitoring of WIOA Programs Interim Policy & Procedures Purpose This document establishes the interim policy to insure that Workforce Innovation and Opportunity Act (WIOA) programs funded through NOVA are operated in compliance with applicable Federal, State and City rules and regulations. Note: Until the Employment Development Department (EDD) establishes guidance using the WIOA Notice of Proposed Rule Making (NPRM) or WIOA Final Regulations, NOVA and its subrecipients will continue to follow the procedures policy in place under WIA. Policy In accordance with EDD directive WIAD 00-7, NOVA develops and implements procedures for monitoring in- house and subcontracted WIOA programs and services to ensure that: 1. programs and services are operated in compliance with WIOA and applicable Federal, State, and City rules and regulations; 2. tangible outcomes are accomplished at costs which are in line with original planned costs; 3. fiscal integrity is insured and auditable records are maintained; 4. services and training are being provided to participants as described in the agreement document; 5. effective equal employment opportunity guidelines are used in program design and operation; 6. the program and training environment is safe and healthful for participants and staff; and 7. the appropriate verification of eligibility or enrollment of participants is on file. Procedures NOVA shall support monitoring of its operations of WIOA programs and will monitor the operations of subcontracted programs and services, as follows: 1 Rev: 10/15

2 A. Subrecipient Monitoring 1. Subrecipient Determination (Uniform Guidance, ) Subrecipient means a non- Federal entity that receives a sub- award from a pass- through entity to carry out part of a Federal program. Characteristics which support the classification of an entity as a subrecipient include when the entity: determines who is eligible to receive what Federal assistance; has its performance measured in relation to whether objectives of a Federal program were met; has responsibility for programmatic decision- making; has responsibility for adherence to applicable Federal program requirements specified in the award; and in accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of NOVA. 2. Monitoring Frequency and LWDA Responsibility All subrecipients shall be monitored on- site once each program year. If a program extends over multiple program years and includes less than six months in any single program year, that program is not required to be monitored during that year. Where WIOA administrative entities are parties to sub- awards that serve multiple Local Workforce Development Area (LWDA) jurisdictions, the affected areas must coordinate and jointly establish procedures for monitoring such sub- awards. 3. On- site Review On- site reviews will utilize standard monitoring instruments covering the following areas, as applicable: Agency administration Program management Fiscal management MIS documents Participant files Classroom training Participant interviews Health and safety conditions Worksite/internship/externship monitoring If a subrecipient s administrative office/fiscal department is separately located at an inaccessible site or not within a reasonable commute of NOVA, as defined by a 50- mile, one- way drive or greater, NOVA will require that copies of fiscal records of a sufficient nature and sample size are sent to NOVA for review. This does not preclude a site visit to a subrecipient s administrative offices, if warranted. 2 Rev: 10/15

3 4. Monitoring Report Format Within 30 days of the initial monitoring completion, NOVA will transmit a draft report of findings, or a final report if no findings, to the subrecipient. The report will include the following information: Name of subrecipient Agreement number(s) Findings and recommendations Time frames for corrective actions Due date for response A monitoring file will be maintained for each subrecipient, which will contain monitoring reports and follow- up documents, as well as the worksheets, questionnaires, and other back- up information used in the monitoring. Records will be retained per Section C of this policy. 5. Steps to Closure Subrecipients with open findings will have 30 calendar days after receipt of the NOVA monitoring report to address the findings and present corrective actions. Upon receipt of the corrective action report from the subrecipient, NOVA will have 30 calendar days to issue a final monitoring report. If the subrecipient still has open items or pending corrective actions, NOVA will conduct a subsequent monitoring event within three months of the published report to confirm corrective actions have been taken and correct the open items. 6. Follow- up Follow- up contacts will be made to ensure that corrective actions have been implemented. Documentation of follow- up will be maintained in the monitoring file. B. Training Contractor Review 1. Definition of Contractor (Uniform Guidance, ) A contract is for the purpose of obtaining goods and services for NOVA s use and creates a procurement relationship with the contractor. Characteristics indicative of such a relationship are when the contractor: Provides the goods and services within normal business operations; Provides similar goods or services to many different purchasers; Normally operates in a competitive environment; Provides good or services that are ancillary to the operation of the WIOA program; Is not subject to compliance requirements of WIOA as a result of the agreement, though similar requirements may apply for other reasons. A Training Contractor is defined as any organization with whom NOVA contracts or partners with to provide specific outlined training classroom or workplace. 3 Rev: 10/15

4 Where WIOA administrative entities are parties to contracts that serve multiple LWDA jurisdictions, the affected areas may coordinate and jointly establish procedures for monitoring such contracts. 2. Frequency Training Contractors will receive a desk review that ensures that the contractor is in compliance with the terms, conditions, and specifications of their agreement. NOVA may also perform on- site monitoring when warranted. 3. Desk Review A desk review may include: Compliance with the terms, conditions and specifications of the agreement Invoices Client progress reports Participant surveys Certificates Summary of participant performance data Career advisor feedback 4. On- site Review On- site reviews may utilize standard monitoring instruments covering the following, as applicable: Agency administration Program management Fiscal management Participant files Classroom training Participant interviews Health and safety conditions Worksite/internship/externship monitoring If a contractor s administrative office/fiscal department is separately located at an inaccessible site or not within a reasonable commute of NOVA, as defined by a 50- mile, one- way drive or greater, NOVA will require that copies of fiscal records of a sufficient nature and sample size are sent to NOVA for review. This does not preclude a site visit to a contractor s administrative offices, if warranted. 5. Steps to Closure Should the on- site review identify findings in any of the above listed areas, NOVA will have 30 calendar days to transmit a notice in writing of unsatisfactory performance to the contractor with recommendations for correction. The contractor will have 30 calendar days after receipt of the NOVA findings notice to correct the deficiency. NOVA may conduct 4 Rev: 10/15

5 subsequent reviews to ensure that the contractor is meeting expectations. Failure by the contractor to perform any obligations or satisfy any of the terms or conditions under their agreement shall be cause for immediate termination of the agreement C. Confidentiality, Data Availability & Retention 1. NOVA will protect the confidentiality of all monitored data. 2. All written reports and other documentation pertaining to monitoring and other oversight activities will be made available for review by Federal and State officials. 3. Reports and other records of monitoring activities must be retained for three years from the date of submission of the final expenditure reports regarding the funding sources monitored. If any litigation, claim, audit or other action involving the records has been started before the expiration of the three- year period, the records must be retained until completion and resolution of all such actions or until the end of the three year period, whichever is later. 5 Rev: 10/15