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What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
What to expect when you're expecting... The Feds (from ETA)
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What to expect when you're expecting... The Feds (from ETA)

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A presentation prepared by the Boston Regional Office for NYATEP's Spring 2012 Conference. The presentation is designed to give Federal grantees and sub-recipients valuable insights into the Federal …

A presentation prepared by the Boston Regional Office for NYATEP's Spring 2012 Conference. The presentation is designed to give Federal grantees and sub-recipients valuable insights into the Federal perspective of oversight and monitoring requirements with ETA grants.

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  • 1. Employment & Training AdministrationWhat to expect when you’reexpecting… the FedsPresented By:Timothy ThebergeETA – Boston Regional OfficeNYATEP Spring Conference - May 7-9, 2012
  • 2. Employment & Training AdministrationTopics to Discuss • ETA’s Oversight Review Philosophy • OMB Circulars • ETA Core Monitoring Guide • Compliance References • Monitoring Requirements & Responsibilities • Governance 101 • Resources 2
  • 3. Employment & Training AdministrationETA’s Oversight Review Philosophy “I’m from the government and I’m here to help.” 3
  • 4. Employment & Training Administration ETA’s Oversight Review Philosophy• No Surprises – Entrance & Exit Meetings – The rule of three – Grantee participation in review of sub-recipients – Guides and tools provided in advance• Follow the Money – State is the grantee but services are provided locally – Includes the option to interview participants, visit employers and review vendors/providers• If it’s not documented, it didn’t happen – “Documented” doesn’t always mean “paper.” 4
  • 5. Employment & Training AdministrationCompliance vs. Technical AssistanceCompliance Assistance Technical Assistance• “You’re doing it wrong.” • “Here’s how to do it right.”• “You’re still doing it • “Here’s a peer-2-peer wrong.” contact to help you.”• “Congratulations! • “This is a corrective You’re now a high-risk action plan with TAT grantee.” resources to help.” 5
  • 6. Employment & Training AdministrationOMB Circulars The cure for insomnia since 1952. 6
  • 7. Employment & Training Administration Key OMB ReferencesCost Principles The other stuff:• Governments • Single Audit – 2 CFR 225 (A-87) – A-133• Non-Profits – 2 CFR 230 (A-122)• Education – 2 CFR 220 (A-21) 7
  • 8. Employment & Training AdministrationAllowable, Allocable & Reasonable (Oh my!)• Allowable – As provide in OMB Circulars, grant agreement, applicable laws and regulations. – Necessary, reasonable and allocable.• Allocable – Assigning an allowable cost to one or a group of funding streams in “reasonable and realistic proportion to the benefit provided.” – May be indirect or direct.• Reasonable – The prudent person principle applies. – Must receive consistent treatment. – The cost must withstand public scrutiny. – Necessary for the performance of the grant. 8
  • 9. Employment & Training Administration First, know thyself. Education Governments Non-Profit CommercialCost Principles 2 CFR 220 2 CFR 225 2 CFR 230 48 CFR 31 (A-21) (A-87) (A-122)Uniform 29 CFR 95 29 CFR 97 29 CFR 95 29 CFR 95Administrative 2 CFR 215 A-102 2 CFR 215Requirements (A-110) (A-110)Audit A-133 A-133 A-133 29 CFR 96Requirement 9
  • 10. Employment & Training AdministrationCore Monitoring Guide We are not Federal auditors.Part of our job is to audit-proof you. (You’re welcome.) 10
  • 11. Employment & Training Administration • Core Activities – Design and Governance – Program and Grant Management – Financial Management – Service / Product Delivery – Performance Accountability • Additional Guides – ARRA Supplement – Financial Supplement – National Emergency Grants • Under Development – Formula Grant Supplement – Trade 11
  • 12. Employment & Training Administration Core Activities (Sample)Program & Grant Financial Management Management Systems• Objective 2.1: Administrative Controls • Objective 3.1: Budget Controls• Objective 2.2: Personnel • Objective 3.2: Cash Management• Objective 2.3: Civil Rights • Objective 3.3: Program Income• Objective 2.4: Sustainability • Objective 3.4: Cost Allocation• Objective 2.5: Match Requirements • Objective 3.5: Allowable Costs• Objective 2.6: Equipment • Objective 3.6: Internal Controls• Objective 2.7: Procurement • Objective 3.7: Financial Reporting• Objective 2.8: Audit and Audit Resolution• Objective 2.9: Reporting Systems 12
  • 13. Employment & Training Administration Review Report Structure• Findings – Violation of law, regulation, advisory, policy, etc. • The report will provide the citation. – Requires corrective action. – May or may not have associated questioned costs.• Areas of Concern – Not technically a violation or only a minor singular occurrence. – Often a current practice or method that is less than ideal or an area where there is room for improvement. – If not corrected, may lead to a finding.• Noted Practices – Practice or policy that the Regional Office has identified as worthy of note and as a potential resource for others to model. 13
  • 14. Employment & Training AdministrationCompliance References The semi-abridged list. 14
  • 15. Employment & Training Administration Staying Inside the LinesFederal Laws / Regulations: Advisories:• Workforce Investment Act • Training and Employment – 20 CFR 660 Guidance Letter (TEGL)• Wagner-Peyser Act • Unemployment Insurance – 20 CFR 652 Program Letter (UIPL)• Trade Act Grant-Specific: – 20 CFR 617, 618 • Annual Funding Agreement• Social Security Act (UI) • Grant Agreement – 20 CFR 601-616, 625, 640, 650 • Statement of Work / SGAOther: • State and Local Plans• State laws, regulations & policies• Local laws, regulations & policies 15
  • 16. Employment & Training Administration Top Findings• Not reporting expenditures on an accrued basis• Failure to conduct monitoring – Inconsistent treatment of findings and sub-recipients• Lack of written policies & procedures – Not following the above.• Failure to report recipient share• Weak Internal Controls• Lack of documentation in participant files• Procurement• Governance 16
  • 17. Employment & Training Administration Monitoring Requirements & ResponsibilitiesThis isn’t your money, it’s the taxpayers’. 17
  • 18. Employment & Training Administration Who watches the watchers?• Federal – Monitors the primary grantees (states) – Review may occur at state, local and subrecipient level• State (SWIB) – Monitors the local areas (sub-recipients).• Locals (LWIBs) – Monitors One-Stop operators, service providers and subrecipients.• Office of the Inspector General – Monitors everyone. 18
  • 19. Employment & Training Administration Oversight Requirements & Credentials• Federal – WIA Sec. 183 – 29 CFR 97.42 / 29 CFR 95.53• State (SWIB) – 29 CFR 97.40 / WIA Sec. 136(f)(1) – 20 CFR 667.400, 410• Locals (LWIBs) – WIA Sec. 117(d)(4) – 20 CFR 667.410 19
  • 20. Employment & Training Administration Documentation of Effort• All monitoring activity must be documented – Even if there are no findings – If there isn’t a report, it didn’t happen• Resolution of all findings must be documented• Status of questioned costs must be documented• Reports must be addressed to appropriate party – State board, local board, etc.• Monitoring procedures and resolution process must be documented• Recipients and subrecipients must receive equal treatment – A finding is a finding. 20
  • 21. Employment & Training Administration Governance 101Because who does what and how they do it actually matters. 21
  • 22. Employment & Training Administration State Board Membership & Meetings• Most members are appointed by the Governor – The Governor is a member of the State Board – Board Chair selected by the Governor – Most appointments based on recommendations from key groups (unions, trade groups, etc.) – Legislature appoints their own members• Meetings must be open to the public – Agenda must be published – Minutes must be available for review – Key votes must be recorded• Conflict of Interest provisions must be in place and enforced 22
  • 23. Employment & Training Administration State Board Roles & Responsibilities• Lead policy-making body for the workforce investment system – Policy-making under WIA is exclusively the role of the SWIB, not the state workforce agency• Oversight of the workforce system• Development of the state plan – Review of local plans• Development of continuous improvement activities• Designation of local areas• Bi-annual certification of local boards• Development of fund allocation formula• Preparation of the annual report to the Secretary 23
  • 24. Employment & Training Administration Local Board Membership & Meetings• Members are appointed by the Chief Local Elected Official(s)• Board Chair selected by the members (not the CLEO) – Staff to the board reports to the board members (not the CLEO)• Meetings must be open to the public – Agendas must be published – Minutes must be available for review – Key votes must be recorded• Lead policy-making body for the local workforce investment system – Local policy must not contradict state policy• In multi-jurisdictional areas, there should be formal agreements among the local elected officials 24
  • 25. Employment & Training Administration Local Board Roles & Responsibilities• Responsible for selection of One-Stop operators, service providers and youth providers• Responsible for oversight of the above – In partnership with the CLEO• Development of the local plan – In partnership with the CLEO• Development of the local budget – In partnership with the CLEO• Certification of one-stops• Identification of training providers• Negotiation of performance measures• Connections and linkages with economic development and 25 employers
  • 26. Employment & Training AdministrationLocal Elected Official Roles & Responsibilities • Appointment of members to the local board – Does not appoint the chair or hire the executive director • Participates on the board • Serves as the local grant recipient • Liable for any misuse of funds • Selects a fiscal agent • Approves the local plan • Approves the local budget • Does not directly select One-Stop operators or service providers 26
  • 27. Employment & Training Administration Resources Let me Google that for you. 27
  • 28. Employment & Training Administration On The Interwebs• www.doleta.gov• www.oig.dol.gov• www.dol.gov/oasam/grants/grants.htm• www.workforce3one.org – etareporting.workforce3one.org• www.gao.gov• www.whitehouse.gov/omb• www.nawb.org• www.naswa.org 28
  • 29. Employment & Training Administration QUESTIONS?Comments or snide remarks also welcome. 29
  • 30. Employment & Training AdministrationRegion 1 New York State TeamNY State Lead Unemployment InsuranceLee Reynolds John Murphyreynolds.tricia@dol.gov murphy.john@dol.govFiscal PerformancePhil Bombardier Christina Eckenrothbombardier.phillip@dol.gov eckenroth.christina@dol.govTrade DiscretionaryTim Theberge Rochelle Laynetheberge.timothy@dol.gov layne.rochelle@dol.gov 30
  • 31. Employment & Training AdministrationPRESENTED BY:Timothy Thebergetheberge.timothy@dol.gov617-788-0139 31

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