DOL MONITORING GUIDE PUTTING YOUR HOUSE IN ORDER

CORE ACTIVITY 1 DESIGN & GOVERNANCE

CORE ACTIVITY 1 DESIGN AND GOVERNANCE Objective 1.1: Strategic Planning Objective 1.2: Service Design Objective 1.3: Program Integration

Do you have an integrated relationship with:  Local workforce development system? - WIB’s, Youth Council, One Stops  Business and industry representatives? - Employers, Chambers, Unions, Associations  Education and training providers? - 4 yr Colleges & Universities, Community Colleges, Trade Schools, Vocational Training Institutions, Skill Centers & Adult Ed providers

YOUTHBUILD DIRECTORS SHOULD: Ensure that workforce development relationships are formalized and tracked through MOU’s, subcontracts, etc Have a strong connection to business and industry through marketing campaigns, service offerings to potential employers, and interaction with chambers and business associations. Access and analyze LMI data regularly, and use relevant statistics to help drive program and curriculum development. Designate a staff person within the program or organization to interact with business and industry and act as a liaison with job seeking participants and potential employers. Identify high-growth businesses and industries within the local economy and their workforce needs. Identify the skills and competencies needed to perform jobs in these key business areas. Have a structured system for employer and business and industry feedback.

CORE ACTIVITY 2 PROGRAM & GRANT MANAGEMENT SYSTEMS

Program and grant management systems support grant functions or activities that are necessary for the operation of a project but are not related to the direct provision of services. PROGRAM AND GRANT MANAGEMENT

The purpose of the Core Activity 2 monitoring component is to evaluate the grantee’s capacity to perform the broad management functions that are required when operating federally funded workforce development grants.

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 PROGRAM AND GRANT MANAGEMENT

Ensure that all of the agency’s policies and procedures manuals are up to date Ensure the DOL EEO Notice is posted and signed in files! Reports are submitted on time Ensure the match is documented and listed on the QPR Ensure equipment (over $5000) has been approved prior to purchase and the equipment was procured correctly YOUTHBUILD DIRECTORS SHOULD:

CORE ACTIVITY 3 FINANCIAL

BUDGET CONTROLS Let’s look at how your program tracks YouthBuild expenditures : Is there an internal YouthBuild budget that breaks down money into practical line items, not just the broad SF424 budget? Are both fiscal and YouthBuild Director familiar with budget line items? What accounting software is used? How are you tracking your match?

Ask fiscal staff if they have a good understanding of YouthBuild. Then, do they have a projected budget figures and actual expenses, with back-up documentation? Take the time to invite fiscal staff to the program or at least give them the story of program ebb and flow YOUTHBUILD DIRECTORS SHOULD:

CASH MANAGEMENT This is primarily a fiscal function but directors can assist: How often are draws necessary? Is the timing of the draw close to disbursement? Are the costs allowable?

PROGRAM INCOME Is the organization aware of the requirements for earning, spending and reporting program income? Just what is Program Income? Program income is revenue that a non- profit receives. It is required to be rolled back into program operations.

ALLOCATION OF COSTS Cost allocation is basically how you decide who and what get the grant award monies Is there an indirect cost rate or an allocation plan for the cost allocation? If the organization has a DOL grant, an education grant and a foundation grant for the education component, and the teacher teaches YouthBuild and other youth, what funding will pay the teacher? Answer: Cost allocation is how much of the DOL $ will pay the teacher based on the time spent with DOL YouthBuild students!

Organization has a system to ensure that costs are necessary, reasonable and allowable Another good place to ask about Policies and Procedures manuals! Manuals should indicate how necessary, reasonable costs are determined ALLOWABLE COSTS

INTERNAL CONTROLS This is the three – pronged accountability approach. To demonstrate integrity an organization can apply GAAP principles. They can also be sure that the 3 point of the triangle reflect three areas of accountability. For example, a staff person cannot approve their own expenditures, or sign their own checks. Mail should be opened with checks logged in. A different person should deposit the funds in the bank. You get the picture!

FINANCIAL REPORTING This is critical and future sustainability may well depend upon it. Reports need to be: Accurate Timely Truthful This includes sub-recipient information Aligned with your policies and procedures Has the report been proofed by the Executive Director/ Director

CORE ACTIVITY 4 SYSTEMS, PROCEDURES & OPERATIONS

Core Activity 4 addresses the systems, procedures, and program operational elements that are essential to the effective delivery of participant and employer services or the development of a product.

OPERATING SYSTEMS: YOUTHBUILD DIRECTORS SHOULD: Be providing the full range of services stipulated in the grant agreement. Be recruiting and screening participants who meet the target group criteria identified in the grant. Ensure that subrecipients and contracts called for in the SOW are in place and fully operational.

PARTICIPANT FILES: YOUTHBUILD DIRECTORS SHOULD: Ensure that the eligible target population identified in the grant is served. Ensure that an individual service plan is developed that identifies and meets the specific needs of each individual participant. Ensure that supportive services are being provided as needed to overcome client barriers to participation and completion of the individual service plan. Ensure participants are receiving training as needed and progressing toward achieving their education/employment goals.

HIGH-GROWTH JOBS: THE GRANTEE PROVIDES EMPLOYMENT AND TRAINING SERVICES THAT TARGET HIGH-GROWTH JOBS WITHIN EXPANDING ECONOMIC SECTORS. YOUTHBUILD DIRECTORS SHOULD: Provide information on high-growth occupations and regional economic trends to job seekers and employers Provide training activities that concentrate in occupational areas having high-demand jobs in high-growth sectors. Provide effective job search and job placement services to place participants in high-growth occupational areas.

INTEGRATED SERVICES: YOUTHBUILD DIRECTORS SHOULD: Coordinate service delivery with other workforce agencies to provide integrated services to customers Make contact with the local WIB to introduce program to the local workforce agencies Ensure that duplicative employer contact is minimized by program participants.

BUSINESS RELATIONSHIPS: YOUTHBUILD DIRECTORS SHOULD: Tailor the delivery of its services and participants to meet the needs of business. Develop an industry council of employers that work with the program to provide the employers with employees ready to work.

CORE ACTIVITY 5 PERFORMANCE ACCOUNTABILITY

THE PURPOSE OF PERFORMANCE ACCOUNTABILITY IS: To determine whether you are meeting your operating goals- Progress to date, capacity to comply, accountability, use of performance data to evaluate and improve the quality od the services and products delivered

SERVICE GOALS WHAT IS IN THE SOW? Project Goals? Activities Spending Targets Timeframes Does your current implementation reflect the SOW? If not, are you able to explain the changes? If yes, are they written and ready for presentation? IS SPENDING CONSISTENT? Is there a balance between spending at a consistent rate so you don’t run out of money, and spending in accordance with program flow? The real program is not always an SF424 annual budget figure divided by 4!

TO MEET OR EXCEED THE PERFORMANCE OUTCOMES, THAT IS THE QUESTION? Will performance measures be met by the end of the grant period?

SUBRECIPIENT PERFORMANCE Dear Grantee: Your subrecipients are your responsibility. You must: 1.Be sure they meet performance measures (if they don’t, you won’t) 2.Is a clear and accountable sub-contract in place? 3.Do they understand the performance measures they must meet? 4.Can they demonstrate planned vs. actual accomplishments 5.Is there a consequence if the sub-contractor does not perform as they should? All of this should be documented and ready for presentation, if requested.

PERFORMANCE DATA Program uses data Findings from reviews are communicated Information is used for improvement in program Program utilizes and gives TA to subrecipients to improve Performance info is provided to stakeholders and used in decision making

You will have an exit conference (usually by phone) with your Federal Project Officer They will give you their positive observations, program findings and areas of improvement They will mail you report within 30 days You will have 30 days to respond to your findings with corrective actions attached AFTER THE MONITORING REVIEW

DOL Regulations (29 CFR): TITLE 29—Labor PART 95--GRANTS AND AGREEMENTS WITH INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS, AND OTHER NON-PROFIT ORGANIZATIONS, AND WITH COMMERCIAL ORGANIZATIONS, FOREIGN GOVERNMENTS, ORGANIZATIONS UNDER THE JURISDICTION OF FOREIGN GOVERNMENTS, AND INTERNATIONAL ORGANIZATIONS idx?c=ecfr&tpl=/ecfrbrowse/Title29/29cfr95_main_02.tpl PART 97--UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS idx?c=ecfr&tpl=/ecfrbrowse/Title29/29cfr97_main_02.tplhttp://ecfr.gpoaccess.gov/cgi/t/text/text idx?c=ecfr&tpl=/ecfrbrowse/Title29/29cfr97_main_02.tpl