Sub-state Monitoring Policy

Issuance No: P7
Issuance Date: April 26, 2016; revised 9/29/16, 3/6/18, 12/03/19
Subject: Sub-state Monitoring Policy

In accordance with OWD Issuance 16-2018

Responsible Representative:  The Northwest Workforce Development Board (NW WDB) Program Operations Manager, Fiscal Manager and Equal Opportunity Officer are responsible for monitoring activities. The NW WDB does not operate programs, all programs are operated by sub-recipients, and therefore the selected monitors are independent from the duties or systems being monitored.

Accountability:  NW WDB staff prepares and submits annual monitoring reports to the NW WDB Board, Chief Local Elected Officials (CLEOs), and Office of Workforce Development (OWD).

Compliance and Performance:  The annual monitoring reports review compliance with the terms and conditions of each contractual scope of work.

  • Program monitoring is a review of the customer’s program eligibility documentation, adequacy of assessment, employment plan, planning of activities and services, appropriateness and accuracy of data entry, participant payments and training payments, coordination with One-Stop System partners to meet the comprehensive needs of customers, and customer outcomes. Each service provider and each funding stream will be monitored annually by the NW WDB Program Operations Manager and presented to the Board.
    • WIOA Youthprogram monitoring will take into account:
      • Out-of-School Youth 75% expenditure requirement
      • 20% work-based learning with educational component requirement
      • 5% limit on In-School Youth enrolled with the “Requires additional assistance” barrier
      • 5% over-income exception, and
      • New eligibility criteria and barriers
  • Equal Opportunity monitoring of each service provider is conducted annually by the local Equal Opportunity Officer to ensure compliance with 29 CFR  Part 37 (Implementation of the Nondiscrimination and Equal Opportunity Provision of the Workforce Investment Act of 1998), 29 CFR Part 38 (Implementation of the Nondiscrimination and Equal Opportunity Provision of the Workforce Innovation and Opportunity Act), and the State of Missouri Methods of Administration In Compliance with the Workforce Investment Act Concerning Non-Discrimination and Equal Opportunity.  To conduct this monitoring, the Local EO Officer will prepare a document to be used by each service provider as a desktop review.  This review will be submitted to the Local EO Officer at least one (1) week prior to the onsite review.  The Local EO Officer will use this desktop review to find shortfalls that could lead to noncompliance.  The Local EO Officer will then prepare a tool to use onsite to investigate potential issues of noncompliance.  While onsite the EO Officer will conduct 2 (two) interviews, one (1) with a staff member, one (1) with a participant.   After the EO Officer has completed the onsite review, he/she

will prepare a final report within two (2) weeks which will include any corrective action for the service provider. The NW WDB will use OWD Issuance 07-2017 (Nondiscrimination and Equal Opportunity [EO] Corrective Actions/Sanction Policy and Guidelines) to create and enforce corrective action plans issued to subcontractors as needed.

  • Fiscal monitoring will be conducted on-site annually to ensure fiscal integrity.  Monitoring will be conducted to comply with WIOA Section 184 (a) (4) [29 U.S.C. 3244(a) (4)], annual OWD agreements, and 2 CFR Part 200 and Part 2900. The financial review will ensure adequacy of internal controls and the reliability of the sub- recipient’s financial management systems as they relate to the administrative sub-award. This monitoring review will ensure that the sub-recipient meets the terms and conditions of the sub-award and the fiscal goal or requirement, and that amounts reported are accurate, allowable and supported by documentation and properly allocated. The monitoring review will result in a written report to the WDB identifying areas of noncompliance and recommendations.  The review will include, but will not be limited to, reviews of the following processes:  financial reporting, internal controls, source documentation, cost allocation/indirect costs, cash management, procurement and inventory review.

Compatibility:  The monitoring tools used by the NW WDB staff are updated annually to be in compliance with WIOA regulations, OWD policies, and NW WDB policies.

Quality Assurance:  Monitoring efforts include a comprehensive examination of prior federal, state and local compliance reviews. Monitoring reports address the corrective action steps and the effectiveness of those actions.  Training and technical support is provided.

Methodology and Target Universes:  NW WDBuses random-sampling techniques in participant file reviews to test eligibility in every funding stream.  Sample sizes and universes are determined by following the guidance found in OWD Issuance 16-2018 Statewide Sub-State Monitoring Policy. Data Element Validation (DEV) will be conducted annually to ensure the integrity of performance outcomes.  The DEV will be performed to conform to the State procedures complying with WIOA Section 116(d)(5) and federal guidance.   The NW WDB Program Operations Manager will ensure the performance data elements are valid, accurate, reliable, and comparable across programs.  Results of the DEV will identify anomalies in the data, will resolve issues that may cause inaccurate reporting, and will improve program performance accountability. The Program Operations Manager will use random-sampling techniques when selecting the exited files to review; the results of DEV will be presented during annual monitoring reports to the CLEOs and NW WDB.