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 perspective of oversight and monitoring requirements with ETA grants.

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

  1. 1. Employment & Training AdministrationWhat to expect when you’reexpecting… the FedsPresented By:Timothy ThebergeETA – Boston Regional OfficeNYATEP Spring Conference - May 7-9, 2012
  2. 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. 3. Employment & Training AdministrationETA’s Oversight Review Philosophy “I’m from the government and I’m here to help.” 3
  4. 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. 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. 6. Employment & Training AdministrationOMB Circulars The cure for insomnia since 1952. 6
  7. 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. 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. 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. 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. 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. 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. 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. 14. Employment & Training AdministrationCompliance References The semi-abridged list. 14
  15. 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. 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. 17. Employment & Training Administration Monitoring Requirements & ResponsibilitiesThis isn’t your money, it’s the taxpayers’. 17
  18. 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. 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. 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. 21. Employment & Training Administration Governance 101Because who does what and how they do it actually matters. 21
  22. 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. 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. 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. 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. 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. 27. Employment & Training Administration Resources Let me Google that for you. 27
  28. 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. 29. Employment & Training Administration QUESTIONS?Comments or snide remarks also welcome. 29
  30. 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. 31. Employment & Training AdministrationPRESENTED BY:Timothy Thebergetheberge.timothy@dol.gov617-788-0139 31

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