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What to expect when you’re expecting… the Feds Presented By: Timothy Theberge ETA – Boston Regional Office NYATEP Spring Conference - May 7-9, 2012. ETA’s Oversight Review Philosophy OMB Circulars ETA Core Monitoring Guide Compliance References Monitoring Requirements & Responsibilities

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  1. What to expect when you’re expecting… the FedsPresented By:Timothy ThebergeETA – Boston Regional OfficeNYATEP Spring Conference - May 7-9, 2012

  2. ETA’s Oversight Review Philosophy • OMB Circulars • ETA Core Monitoring Guide • Compliance References • Monitoring Requirements & Responsibilities • Governance 101 • Resources Topics to Discuss

  3. ETA’s Oversight Review Philosophy “I’m from the government and I’m here to help.”

  4. 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.”

  5. Compliance vs. Technical Assistance Compliance Assistance • “You’re doing it wrong.” • “You’re still doing it wrong.” • “Congratulations! You’re now a high-risk grantee.” Technical Assistance • “Here’s how to do it right.” • “Here’s a peer-2-peer contact to help you.” • “This is a corrective action plan with TAT resources to help.”

  6. OMB Circulars The cure for insomnia since 1952.

  7. Key OMB References Cost Principles • Governments • 2 CFR 225 (A-87) • Non-Profits • 2 CFR 230 (A-122) • Education • 2 CFR 220 (A-21) The other stuff: • Single Audit • A-133

  8. Allowable, 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.

  9. First, know thyself.

  10. Core Monitoring Guide We are not Federal auditors. Part of our job is to audit-proof you. (You’re welcome.)

  11. 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

  12. Core Activities (Sample) Program & Grant Management • Objective 2.1: Administrative Controls • Objective 2.2: Personnel • Objective 2.3: Civil Rights • Objective 2.4: Sustainability • Objective 2.5: Match Requirements • Objective 2.6: Equipment • Objective 2.7: Procurement • Objective 2.8: Audit and Audit Resolution • Objective 2.9: Reporting Systems Financial Management Systems • Objective 3.1: Budget Controls • Objective 3.2: Cash Management • Objective 3.3: Program Income • Objective 3.4: Cost Allocation • Objective 3.5: Allowable Costs • Objective 3.6: Internal Controls • Objective 3.7: Financial Reporting

  13. 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.

  14. Compliance References The semi-abridged list.

  15. Staying Inside the Lines Federal Laws / Regulations: • Workforce Investment Act • 20 CFR 660 • Wagner-Peyser Act • 20 CFR 652 • Trade Act • 20 CFR 617, 618 • Social Security Act (UI) • 20 CFR 601-616, 625, 640, 650 Other: • State laws, regulations & policies • Local laws, regulations & policies Advisories: • Training and Employment Guidance Letter (TEGL) • Unemployment Insurance Program Letter (UIPL) Grant-Specific: • Annual Funding Agreement • Grant Agreement • Statement of Work / SGA • State and Local Plans

  16. 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

  17. Monitoring Requirements & Responsibilities This isn’t your money, it’s the taxpayers’.

  18. 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.

  19. 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

  20. 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.

  21. Governance 101 Because who does what and how they do it actually matters.

  22. 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

  23. 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

  24. 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

  25. 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 employers

  26. Local 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

  27. Resources Let me Google that for you.

  28. 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

  29. QUESTIONS? Comments or snide remarks also welcome.

  30. Region 1 New York State Team NY State Lead Lee Reynolds reynolds.tricia@dol.gov Fiscal Phil Bombardier bombardier.phillip@dol.gov Trade Tim Theberge theberge.timothy@dol.gov Unemployment Insurance John Murphy murphy.john@dol.gov Performance Christina Eckenroth eckenroth.christina@dol.gov Discretionary Rochelle Layne layne.rochelle@dol.gov

  31. PRESENTED BY: Timothy Theberge theberge.timothy@dol.gov 617-788-0139

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