Oregon WIA Administration Conference August 20, 2013

1. Oregon WIA Administration Conference August 20, 2013 Monitoring in Oregon

2. Monitoring • Purpose • Process • Resources • Q and A Session

3. Purpose Ensure Compliance Comply with The Workforce Investment Act Comply with Federal Regulations Result in Possible Waiver of Disallowed Costs

4. Purpose (Continued) Help local areas stay informed Provide consistent, annual process Ensure that policy is established if needed Provide on-site technical assistance as needed

5. Isn’t an Audit Enough? • No—you can only learn so much from a Single Audit of an entity administering multiple funding sources. • Fiscal monitoring has revealed non-compliance that slipped through years of audits.

6. Purpose (Continued) As a Management Tool • Prevent violations of WIA • Detect potential disallowed costs early • Prevent or discover fraud of abuse • Can eliminate bottlenecks, streamline coordinated efforts and improve cost effectiveness

7. Monitoring Process http://oregonmonitoringpy2013.weebly.com/ Chronology • Summary letter and monitoring guide • Schedule site visits • Desk reviews, coordination and planning • Site Visits – entrance, review, draft report and exit

8. Monitoring Guide Key Changes for PY 2013 Administrative • A-12. Added “identify the last date the one stop was certified”. • A-20. Added “Please describe your measurable contract goals and means of evaluating service provider’s performance (youth)”. • A-21. Added “guide youth policy, develop the youth portion of the youth plan”.

9. Monitoring Guide Key Changes for PY 2013 Fiscal • F-17. Added “a list of current contracts with expiration dates.” • F-23. Added CCWD’s Statewide Support Services Policy reference (589-30.12). • F-25. New - $5,000 or more equipment/property purchases and received prior state approval.

10. Monitoring Guide Key Changes for PY 2013 Fiscal (Continued) F-27. New – Procurement > $25,000 listing by type of procurement for sampling/testing local procurement processes and accompanying table. F-28. Added the “Director Termination Review Program”.

11. Monitoring Guide Key Changes for PY 2013 Program P-5. Added “How are these results documented in the individual service strategy (ISS)”. Retired P-18 and P-19 due to I-Trac functionality.

12. Monitoring Guide Key Changes for PY 2013 Program P-44. Added CCWD’s On-the-Job Training Contract Reimbursement Documentation Policy 589-10.19. P-45. New compliance element with WIASRD #349 which requires 12 months of youth follow-up.

13. Program Monitoring http://www.weebly.com/weebly/main.php What are we looking at? Compliance with Local Policies Compliance with CCWD Policies Compliance with DOL Eligibility and Enrollment Data Validation

14. Fiscal Monitoring What are we looking at? Budgeting Systems Internal Controls Accounting Systems Petty Cash

15. Fiscal Monitoring What are we looking at? Cash Receipt and Disbursement Staff & Participant Credit/Debit/Gift Cards Purchasing & Receiving Payroll

16. CCWD Monitoring Report Report Sequence Exit Conversation Draft Report LWIB Response Final Report

17. CCWD Monitoring Report Source: CCWD Policy 589-40.1 Possible Report Notes Observation:The identification of a current item or issue discovered in the course of a review that involves system/procedural problems that need immediate attention, but are not serious and/or material enough to warrant being categorized as a finding. The recommendation would identify whether the sub-recipient needs to respond in writing concerning action taken to address the recommendation.

18. CCWD Monitoring Report Source: CCWD Policy 589-40.1 Possible Report Notes Finding:The identification of an item or issue that is of a significant concern or indicates the violation of a guiding principle or requirement. Prior to identifying a finding, the standard operating procedure is for State staff to confer with sub-recipient staff on whether the item or issue was an abnormality/exception.

19. CCWD Monitoring Report What do you do if you disagree? Local staff have 30 days from the exit interview to develop and send a response to the draft report. CCWD finalizes and forwards final report to LWIB within two weeks of receipt of LWIB response. Local staff can then submit a formal appeal to the Commissioner if still in disagreement.

20. Common Findings Examples Contract or professional services payments not supported by signed contract/agreement Labor distribution errors Cash Account reconciliations not approved by second party in timely manner

21. Common Findings (Continued) Examples • Incentive payments to participants not agreeing to adopted fee schedule • Sub-recipient monitoring • Non-expendable property records

22. Common Findings (Continued) Examples • Travel expenditures for board members • Termination payments to Executive Directors • Lack of prior approval from CCWD • Not following local policies with discretionary grants (NEG, SESP, etc.)

23. Other Changes Possible Changes to Single Audit Act OMB Raising limit for Single Audit Reducing number of major compliance areas Combining cost principles Updating selected areas of cost

24. Resources Procuring Audits New CD on how to procure an audit Local areas can check it out from CCWD Follow your Local Procurement Policy

25. Resources Monitoring Website http://oregonmonitoringpy2013.weebly.com/ CCWD WIA 1B Policies http://www.oregon.gov/ccwd/Pages/rap/wia1b.aspx Workforce Development Statewide Policies http://www.oregon.gov/ccwd/Pages/rap/statewide.aspx

26. Q and A

27. Resources – CCWD Contacts Program and Administrative • Michael D McCoy (michael.d.mccoy@state.or.us) • John Asher (John.Asher@state.or.us) Fiscal • Debra Welter (debra.welter@state.or.us)