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Program and Compliance Management. V I R T U A L L Y. Opening Session: PERSPECTIVES ON ACCOUNTABILITY. Outline. Key Attributes Your Compliance Playbook The Forest, The Trees and Performance Management The Zen of Reporting Data, Data Everywhere. INTRODUCTION.

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Program and compliance management

Program and Compliance Management

V I R T U A L L Y

Opening Session:

PERSPECTIVES ON ACCOUNTABILITY


Outline
Outline

Key Attributes

Your Compliance Playbook

The Forest, The Trees and Performance Management

The Zen of Reporting

Data, Data Everywhere


Introduction
INTRODUCTION

  • Which of the following statements describes your thoughts/opinions about performance and performance data?

    • I get warm fuzzies

    • Performance accountability is my friend

    • I’d rather have root canal

    • I don’t think it’s meant to be understood

    • It’s something for techies, right?


Key Attributes of Accountability

within the Framework of Program & Compliance Management


  • Universality

    • All levels, entities, individuals

  • Relativity

    • It’s all relative for all of the above


Questions based on the universality and relativity of accountability
QuestionsBased on the Universality and Relativity of “Accountability”

What’s another way of saying The National Context?

The _i_ P_ _ t u _ _

B_ _ _ nd the S _ _ _ es

What does Isaac Newton’s theory have to do with accountability?

Accountability flows ___________.


The national context
The National Context

Government Performance & Results Act of 1993

Applies to federal agencies but many implications for ___________ and ____________

Primary purpose to inform Congressional decision-making and institutionalize results-driven government

Referenced often

Funding decisions tied to performance outcomes based on solid data


A universal accountability framework
A Universal Accountability Framework

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework1
A Universal Accountability Framework

Authorizing Statute

with associated regs

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework2
A Universal Accountability Framework

Authorizing Statute

with associated regs

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework3
A Universal Accountability Framework

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework4
A Universal Accountability Framework

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

P.L. 107-288

(JVA)

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework5
A Universal Accountability Framework

ETA Policies

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

P.L. 107-288

(JVA)

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework6
A Universal Accountability Framework

GRANT AGREEMENT

ETA Policies

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

P.L. 107-288

(JVA)

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework7
A Universal Accountability Framework

SGA

Solicitation for Grant Applications

GRANT AGREEMENT

ETA Policies

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

P.L. 107-288

(JVA)

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


A universal accountability framework8
A Universal Accountability Framework

OMB-Approved Reporting

GRANT AGREEMENT

SGA

ETA Policies

2 CFR

Formerly OMB Circulars

Authorizing Statute

with associated regs

P.L. 107-288

(JVA)

29 CFR

PROGRAM & COMPLIANCE MANAGEMENT


Your Compliance Playbook


Remember the compliance hierarchy
Remember the Compliance Hierarchy

  • Statute

  • Regulations

  • Policy


Playbook contents not an exhaustive list
Playbook Contents Not An Exhaustive List!

  • Statute

    • P.L. 105-220 (WIA)

    • P.L. 107-288 (JVA)

  • Regulations

    • 29 CFR Part 95 and Part 97

    • 29 CFR Part 37

    • 20 CFR Part 652, et al. (WIA Regs)

    • 2 CFR

  • Policy

    • Training and Employment Guidance Letters (TEGLs)

    • Training and Employment Notices (TENs)

    • http://wdr.doleta.gov/directives


State local playbook extras
State/Local Playbook “Extras”

Local leadership further defines policy and procedural guidance based on all of the above and as appropriate


Reflections
Reflections

What’s your playbook status?


The Forest, The Trees and Performance Management


Fill in the blanks
Fill in the Blanks

  • Performance _________

  • Performance _________

  • Performance _________

  • __________ Management

  • __________ Management

  • __________ Management


Performance management as forest
Performance Management as Forest

  • …with lots of trees

    • Performance measurement

    • Data collection

    • Data analysis

    • Customer satisfaction surveying

    • Reporting results

    • Contract administration

    • Etc.

  • Translation: Performance measurement is part of performance management – they are not synonymous


Who cares
Who Cares?

Perceptions drive behavior

The measurement aspect may be the purview of a few technical or MIS staff but the management aspect is everyone’s business – every staff person from the One-Stop ‘greeter’ to the Executive Director

So whose performance is it anyway


The bottom line
The Bottom Line

  • From an organizational perspective (irrespective of “level”) we’re all responsible for grants management or program management or compliance management

  • From an individual perspective (irrespective of “level”) we’re all responsible for performance management



A 10 000 foot view
A 10,000 Foot View

National Reports and Analyses


Every one counts
Every “One” Counts

  • From secretary to Secretary

  • Decisions, decisions . . .

  • Data entry – Timely and Accurate

  • Know your MIS

  • If you think you’re too small to make a difference, you’ve never been in bed with a mosquito


Program reporting summed up
Program Reporting Summed Up

  • Who You’re Serving

  • What They’re Getting

  • With What Results


If it’s not reported,

it never

happened


The wiasrd workforce investment act standardized record data
The WIASRDWorkforce Investment Act Standardized Record Data

  • Individual records for current and former WIA participants submitted on quarterly basis

  • Basis of WIA aggregate reporting

  • TEGL 17-09 required for the first time quarterly records on participants, not just exiters

    • Affords unprecedented level of analysis


Quarterly wiasrd submissions tegl 17 09 3 10 10 page 2
Quarterly WIASRD SubmissionsTEGL 17-09, 3/10/10, Page 2

  • “With more timely detailed information, ETA will be able to perform more in-depth program analysis and assessment. Decisions will be better informed, and states will gain access to frequent updates on nationwide trends in participant characteristics, training, employment services, and outcomes.”


Caution
Caution:

The WIASRD isn’t just for MIS, reporting or performance staff

It’s the foundation for WIA accountability! (including data validation)

It contains information program staff need (like definitions and their nuances)

Some states put key aspects of the WIASRD into state program guidance (e.g., eligibility)



Context is critical
Context is Critical

“The bad news is, you do less work than anyone in this office.

The good news is, you make the fewest mistakes.”


Garbage in garbage out
Garbage In Garbage Out

  • “The government is very keen on amassing statistics. They collect them, add them, raise them to the nth power, take the cube root, and prepare wonderful diagrams. But you must never forget that every one of these figures comes in the first instance from the village watchman, who just puts down what he pleases.”

Question: Who’s the village watchman?


Caveat emptor
Caveat Emptor

  • Know the context and be an informed consumer of information

  • Our data tell a story; Your data tell a story

  • …so what does it say?


About the workshops in this conference
About The Workshops in this Conference

Information that supports workforce development accountability, compliance and data management

Findings/Concerns from data validation reviews highlighted

National, Regional, State, Local WIASRD data discussed

Etc.


We ve only just begun
We’ve Only Just Begun!


Accountability a universal framework

Accountability: A Universal Framework

Appendix

Approved

Reporting

Instructions

SGA

Grant

Agreement

ETA Policies

Authorizing

Statute

29 CFR

OMB

Circulars

(2 CFR)

Jobs for

Veterans

Act

Program & Compliance Management


  • Authorizing Statute

    • In most cases, the Workforce Investment Act or WIA is the authorizing statute (Sec. 171 of WIA authorizes pilot and demonstration projects). Note that the WIA regulations would apply.

    • Earmark grants are authorized by appropriations legislation

  • 29 CFR (Code of Federal Regulations)

    • Parts 95 and 97 contain uniform administrative requirements (e.g., grantees are responsible for managing their projects, including sub-recipient activities and services; includes requirements pertaining to data collection and reporting)

    • Part 37 contains implementing regulations for the non-discrimination and equal opportunity provisions of WIA Sec. 188

  • OMB Circulars

    • Includes cost principles (e.g., OMB Circular A-21 covers institutions of higher education)

    • Circulars now codified under 2 CFR

  • Jobs for Veterans Act

    • Public Law 107-288 pertains to all DOL-funded employment and training programs and establishes ‘priority of service’ for veterans and eligible spouses

  • ETA Policies

    • Training & Employment Guidance Letters (or TEGLs) covering a range of topics, including salary and bonus limitations (TEGL 5-06) and the definitions of key terms such as ‘participant’ and ‘exiter’ contained in TEGL 17-05

  • SGA (Solicitation for Grant Application)

    • Contains grant-specific and/or program-specific information; grantees agree to provisions as condition of award receipt. (The SGA could clarify that certain activities and/or expenditures are unallowable for the particular grant.)

  • Grant Agreement

    • This is the agreement between USDOL and the grantee organization. It contains the Statement of Work (SOW) and performance expectations

  • Approved Reporting Instructions

    • The OMB-approved ETA 9130 is required of all USDOL/ETA grantees for quarterly financial reporting

    • Programmatic reporting is different across the core workforce programs (different reports for Wagner-Peyser and WIA) and it also differs across discretionary grantees (based on OMB-approved reporting instructions for the specific type of grant).


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