1. U.S. Department of Labor Employment and Training Administration MONITORING 201: What To Expect In A Program (Participant) And Financial Review Webinar Date: September 15, 2015 2:00PM EST U.S. Department of Labor Employment and Training Administration

2. Learning Objectives Purpose Why and How We Monitor Enhanced Desk Review vs. Onsite Review Core Monitoring Guide Program (Participant) Objectives Financial Objectives included in the Financial Supplement Monitoring Report and Resolution Process Common Findings Suggestions for Avoiding Findings Review Participant Files 2

3. Presenters Moderator & Program (Participant) Files: Maisha Meminger, Division of Youth Services, National Office USDOL Program Monitoring Review Content: Elina Mnatsakanova, Federal Project Officer, Region 6 USDOL Fiscal Monitoring Review Content: Debbie Galloway, Senior Fiscal Analyst, Office of Grants Management, National Office USDOL 3

4. Purpose of Monitoring U.S. DOL ETA conducts monitoring to Ensure compliance with: Federal financial and administrative requirements, statutes, and regulations Grant Agreement terms and conditions Solicitation for Grant Applications (SGA) Identify technical assistance needs and best practices. 4

5. Monitoring Methods On-Site Monitoring Review Scheduled at least 30 days in advance Conducted on-site in 2 – 5 days Enhanced Desk Monitoring Review (EDMR) Scheduled at least 30 days in advance Conducted virtually in 2 – 5 days 5

6. On-Site Monitoring Reviews 6

7. Core Monitoring Guide “Generic” tool, includes five core activities: 1.Design and Governance 2.Program and Grant Management Systems 3.Financial Management Systems 4.Service Delivery 5.Performance Accountability Financial Supplement Focuses on core activities 2 & 3 and includes additional objectives (2.11, 2.12 and 3.9) 7

8. Scheduling The Review Establish the dates of the review Issue formal review confirmation letter Sent at least 30 days prior to visit to grant’s authorized representative (cc. grant’s program manager or POC) Includes US DOL ETA Core Monitoring Guide and Review Planning Tool Confirm staff availability Identify records, policies and files needed for review 8

9. Review Planning Tool Developed to supplement Core Monitoring Guide Lists documents to be reviewed Identifies key staff and partners to be interviewed. Used to develop review Agenda

10. Entrance Conference Reviewer(s) and grantee staff Duration: 30 minutes Discuss the review process and next steps Finalize the agenda Q & A Select a sample of participant files for review Optional: a list of participants is requested prior to visit 10

11. Core Activity 1: Design and Governance Objectives: 1.1 Strategic Planning 1.2 Service Design 1.3 Program Integration 11

12. Core Activity 1: Design and Governance How are you operating your program? Is your program structured as described in the grant agreement scope of work? Is your program fully integrated and aligned with other community resources? Have you strategically developed partnerships in your community to support your program? Are the required partners on-board with your grant program ? 12

13. Core Activity 2: Program and Grant Management Systems 2.1 Administrative Controls 2.2 Personnel 2.3 Civil Rights 2.4 Sustainability 2.5 Match Requirements 2.6 Equipment 2.7 Procurement 2.8 Audit and Audit Resolution 2.9 Reporting Systems 2.11 Facilities and other Capital Assets 2.12 Intangible Property 13

14. 2.1 Administrative Controls Policies and Procedures for core management functions and program operations (fiscal and program) Monitoring Tools and Procedures and documentation of monitoring sub-recipients Record retention and access policy 14

15. 2.2 Personnel Personnel policies, including hiring process and procedures Grantee Organizational Chart Project Organizational Chart 15

16. 2.3 Civil Rights Access to and within buildings EEO notices in appropriate languages EEO notices in participant files Job announcements in appropriate languages ETA monitoring is a limited review of civil rights and issues related to individuals with disabilities Grievance and complaint procedures Incident reporting 16

17. 2.4 Sustainability If required, there is a viable plan for sustaining grant activities for those grants whose funds are scheduled to expire [Statement of Work (SOW)]. The organization has identified resources that will support project activities after the grant expires. A plan is in place for continuation of services to participants who have not completed the program by the end of the grant period. 17

18. 2.5 Match Requirements Youth Career Connect grantees have a 25 percent match requirement. Written procedures on: Match & leveraged resources requirements Allowable match Methods for tracking Developed Issued to all parties affected Records are available to document and track match 18

19. 2.6 Equipment DOL’s definition for Equipment is any item with a per unit acquisition cost of $5,000 or more, and a useful life of more than one year. Requires Prior approval from DOL Grant Officer Costs are properly allocated Inventories conducted every two years Inventories are properly tracked Use is limited to grant Program income fees charged, if applicable 19

20. 2.7 Procurement Open and fair competition Written procurement procedures for goods and services Basis for contractor selection Justification for sole source All Federal certifications and required clauses Cost and/or price analysis 20

21. 2.8 Audit and Audit Resolution Audit of own organization Audit of sub-recipients Audit tracking system Written status report of questioned costs and findings as a result of the latest Single Audit performed of grantees organization. Resolution 21

22. 2.9 Reporting Systems The organization maintains data collection and reporting systems to fulfill external reporting requirements, both financial and programmatic 22

23. Core Activity 3: Financial Management Systems 3.1 Budget Controls 3.2 Cash Management 3.3 Program Income 3.4 Cost Allocation 3.5 Allowable Costs 3.6 Internal Controls 3.7 Financial Reporting 3.9 Cost Classification 23

24. Basics: Financial Management Systems Must adhere to 7 separate standards Financial Reporting Accounting Records Internal Controls Budget Controls Allowable Costs Source Documentation Cash Management 24

25. Basics: Financial Grant Management Successful & Effective Performance & Grants Management Internal Controls & Budget Control Allowable, Reasonable, & Necessary Costs Accounting Records & Source Documentation 25

26. Financial Management Requirements Effective for YCC grants and for all grants awarded on or before December 26, 2014 Grant Recipients Before December 26, 2014 Admin Requirements Audit Requirements Cost Principles Governmental Organizations 29 CFR Part 9729 CFR Part 962 CFR 225 Non-Profit Organizations 29 CFR Part 9529 CFR Part 962 CFR 230 Institutions of Higher Education 29 CFR Part 9529 CFR Part 962 CFR 220 Commercial For-Profit Organizations 29 CFR Part 9529 CFR Part 9648 CFR 31.2 26

27. Financial Management Requirements Grant funds received after December 26, 2014 must follow he Uniform Guidance Grant Recipients After December 26, 2015 Admin Requirements Audit Requirements Cost Principles Governmental Organizations 2 CFR Part 200 and 2 CFR Part 2900 Indian Tribes Non-Profit Organizations Institutions of Higher Education Commercial For-Profit Organizations * Foreign Public Entities and Foreign Organizations * Please see the Federal Register dated December 19, 2014 outlining the one-year grace period for the implementation of the procurement standards * 2 CFR 2900.2 expands the applicability of the Uniform Guidance to these entities. Uniform Guidance Resources - http://doleta.gov/grants/pdf/quick_reference_sheet.pdf 27

28. Basics: Accounting Records and Source Documentation Accounting Records Must demonstrate the ability to maintain records that adequately identify the source and application of funds for approved financial activities aligned with the SOW. The General Ledger is the official books where all transactions are posted and this information is transferred to ETA’s Quarterly Financial Status Report. Source Documentation Accounting records and payments must be supported by documentation such as actual invoices, canceled checks, time and attendance records, reimbursement to employers for OJT, eligibility for stipends, justification for needs-related payments. 28

29. 3.1 Budget Controls Budget Control Process implemented to compare planned versus actual expenditures to prevent line item overruns Compare monthly or quarterly Compare approved budget to expense reports Need for budget modification? 29

30. 3.1 Budget Controls Budget Control Comparison of budget or planned expenses to actual on a reasonable frequency Flexibility is allowed within the grant budget (except wages, salaries and fringe benefits, and indirect cost rates), provided no single line item is increased or decreased by more than 20% Changes in excess of 20% require prior written approval from the Grant Officer. Failure to obtain such prior approval may result in cost disallowance. For grants awarded after 12/26/2014, the prior approval process will change due to the implementation of the Uniform Guidance. 30

31. 3.2 Cash Management Forecasting cash needs Advances Petty cash & petty check Credit cards / purchasing cards Sub payments advances Authorized to Request and receipt Log in cash receipts Deposits Liquidation of advances 31

32. 3.3 Program Income Revenue in excess of expenses is program income Except for commercial organizations Requirements To further grant activities Separate account codes Expended prior to requesting additional cash Reported on the accrual basis of accounting 32

33. 3.4 Cost Allocation Federally approved indirect cost rate Federally approved cost allocation plan Other cost allocation plans – approved by a State or other Federal agency 33

34. 3.5 Allowable Costs Transaction testing Payroll Space Operations and maintenance Administrative costs Travel Sub-contracts Sub-agreements Inter-agency agreements All Cost Must Be Allowable, Allocable, Necessary, And Reasonable 34

35. 3.6 Internal Controls Separation of duties Transactions properly authorized Assets are safeguarded Budgetary controls exist IT systems are secure 35

36. 3.7 Financial Reporting Reports are submitted to DOL are accurate and timely No less frequently than quarterly Grantee and grantee’s sub-recipients are reporting on the accrual basis of accounting Sub-recipient reporting instructions are issued For all data elements Require reports to be on the accrual basis of accounting 36

37. 3.7 Financial Reporting Track program vs. administrative costs Stay within administrative cost cap limit Apply an approved indirect cost rate correctly Charging all indirect costs as admin? If not charging all indirect costs as admin, what portion of indirect cost pool are properly chargeable to program? 37

38. 3.7 Financial Reporting Grant expenditures must be reported on an accrual basis 38

39. 3.9 Cost Classification Administrative Cost Definition Definition at 20 CFR 667.220 Function based Not related to direct program services Can be both direct and indirect Examples: Accounting, budgeting, financial and cash management Procurement and purchasing Personnel and property management Payroll, audit and general legal services Oversight and monitoring of administrative activities Developing information systems and procedures related to administrative functions 39

40. Core Activity 4: Service / Product Delivery 4.1 Operating Systems 4.2 Participant Files 4.3 High-Growth Jobs 4.4 Integrated Services 4.5 Business Relationships 40

41. Core Activity 4: Service / Product Delivery List of Materials to be Reviewed Outreach and recruitment materials Eligibility procedures and documentation Copy of project plan and contractual agreements Latest participant data from PTS MIS System Training Curriculum, course descriptions, and products developed with grant funds Supportive Services policy and documentation Program Services Flow-Chart Non-Financial MOU’s with partners identified in grant agreement 41

42. Core Activity 5: Performance Accountability 5.1 Service Goals 5.2 Performance Outcomes 5.3 Sub-recipient Performance 5.4 Performance Data 42

43. Core Activity 5: Performance Accountability Project implementation plan Spending targets Performance data reports from PTS MIS system Sub-recipient contracts, performance, and financial reports 43

44. Exit Conference Conducted by the reviewer(s) Reviewer provides an overview of the issues identified during the review. Notes positive practices Discusses next steps: issuance of the monitoring report and subsequent Corrective Action Plans (CAP) Q & A 44

45. Monitoring Report Issued within 45 days after the Exit Conference Consists of a cover letter, executive summary, and actual report Details findings (violations of compliance requirements) and required corrective actions Notes areas of concern Describes promising practices Requires a Corrective Action Plan (CAP) within 30 days of receipt. 45

46. Findings Resolution Process Grantee submits a Corrective Action Plan Discusses actions that will be taken to resolve findings Provides a timeline for all required changes Findings closed, based on CAP Additional CAPs may be required All findings must be resolved by the end of the grant 46

47. Suggestions for Reducing Findings Knowledge and understanding of the: Grant Agreement Solicitation for Grants Application (SGA) Federal statutes and regulations Maintain Documentation Financial activities (e.g. expenditures, procurement actions, etc.) Program or Performance Outcomes Policies and procedures for all grant activities Questions? Call your FPO 47

48. Questions? 48

49. YCC PARTICIPANT (PROGRAM) FILES 49

50. Objectives Review Key FAQs Participant Files Tip Suggested YCC Participant File Documents Resources 50

51. The Resource Guide Contains: Participant Files FAQs Participant Files Tips Suggested YCC Participant File Documents Participant File Resources Emphasizes that each program has proof of services and activities took place for each YCC participant unique to the YCC program; the proof is organized and uniform; and programs have up-to-date notes on each student 51

52. What are the components of a participant file? YCC grant programs are responsible for providing information on each YCC student regarding: eligibility for the YCC program; Equal Opportunity Documents any applicable assessments for the YCC program; education and support received through (or in conjunction with) YCC; Individual Development Plan (IDP) employment and work-experience received through (or in conjunction with) YCC; placement after exit; case notes. 52

53. Are participant files an important a part of the YCC program and monitoring? YES Under the U.S. Department of Labor, Employment and Training Administration, Core Monitoring Guide, Participant Files indicate: 1.The grantee is serving the eligible/target population identified in the grant; 2.The grantee develops an individual service plan (i.e. the Individual Development Plan) identifying and meeting the specific needs to each individual participant; 3.Supportive services are being provided as needed to overcome client barriers to participation and completion of the individual service plan; and 4.Participants are receiving training as needed and progressing toward achieving their employment goals. 53

54. Is the participant file a different file from the student’s school file/record? School File YCC Participant File Assists. PTS 54

55. Can the PTS act as a Student’s Participant File? The PTS is a data collection tool which allows grantees to track specific data elements, by participant, and report against program performance measures. Individual participant files enhance the PTS by housing documentation as proof of services and activities provided 55

56. Do participant files have to be hard copies? This depends on design of the YCC program’s guidelines. Items in a participant file can be electronic, in a physical folder or a hybrid of both. 56

57. How will participant files be used during a monitoring visit? FPOs will pull or request participants’ files randomly to determine whether objectives are being met. If the files are solely electronic, the FPO must have access to those files. They will also interview personnel who manage the participant files. The more comprehensive your files are, including documentation, signatures, case notes, receipts, logs, time sheets, etc. the better. 57

58. U.S. Department of Labor Employment and Training Administration Participant File Tips 58

59. File Maintenance Strongly suggested each YCC program 1.Create a written description of the standards for participant files 2.Establish an internal quality assurance system 3.Create a checklist of what documentation is be in each file 4.Create guidelines for: 1.Recording case notes 2.Organizing participant files 3.Updating documents regularly 4.Ensuring information in file matches PTS 5.Ensuring file protection **Make sure to adhere to Family Educational Rights and Privacy Act (FERPA) regulations** 59

60. U.S. Department of Labor Employment and Training Administration Suggested YCC Participant File Documents 60

61. Note….. Note this is a sample list of SUGGESTED items only and not all of these documents are requirements for the YCC program 61

62. Each folder should have… Parental Permission if under 18 Equal Opportunity Documentation A completed and updated IDP Emergency Contact information Photo Waiver Release of Information (Waivers) for Employers and Educational Institutions Eligibility documents Assessments Records of participation in activities Supportive services Documentation of credentials and diplomas achieved Documentation of other outcomes attained (such as employment) Case notes 62

63. U.S. Department of Labor Employment and Training Administration Monitoring & Participant File Resources 63

64. RESOURCES “ Is Your House in Order?” YouthBuild Video Series (2014) contains 11 videos to help assist grantees in preparation for DOL grant compliance and monitoring reviews, https://www.youtube.com/playlist?list=PLX8R1qzt_6MBNXfTij_r9s19b5ydl2hCk https://www.youtube.com/playlist?list=PLX8R1qzt_6MBNXfTij_r9s19b5ydl2hCk First Step: A student Practitioner’s Resource Guide to Supportive Services (2012) provides youth practitioners with the information needed to connect young adults to those supportive services their employing organizations may not offer. The Guide provides quick and easy access to programs and services at the state or local level. http://wdr.doleta.gov/directives/attach/TEN/TEN_31_12_Att.pdf http://wdr.doleta.gov/directives/attach/TEN/TEN_31_12_Att.pdf Improving Demand-Driven Services and Performance: Toolkit for Effective Front-Line Services for Youth (2007) assists programs with improving case management, recruitment, intake, follow-up services, and developing Individual Service Strategies. Chapter Six, Documentation: Record-Keeping and Case Notes presents a summary of some guidelines for recording case notes, organizing case files, and establishing an internal quality assurance system to facilitate maintaining high standards for documentation in case fileshttp://www.doleta.gov/youth_services/pdf/TOOLKIT%202007-Manual.pdfhttp://www.doleta.gov/youth_services/pdf/TOOLKIT%202007-Manual.pdf 64

65. RESOURCES U.S. Department of Labor, Employment and Training Administration, Core Monitoring Guide (2005) provides a consistent framework and starting point for all on-site grant monitoring responsibilities by ETA. ETA has been moving forward in a coordinated effort to improve the consistency of oversight while relying on and providing opportunities for Federal Project Officers (FPOs) to bring their professional judgments and experience to the process. “Core Activity 4: Service/Product Delivery- Objective 4.2: Participant Files” provides a summary of indicators for review of participant files and case notes, http://www.doleta.gov/regions/reg02/documents/OSID%20Conference/Resource%20- %20Core-Monitoring-Guide.pdf http://www.doleta.gov/regions/reg02/documents/OSID%20Conference/Resource%20- %20Core-Monitoring-Guide.pdf U.S. DOL Core Monitoring Guide Financial Supplement http://www.doleta.gov/regions/reg06/Documents/ConferenceFiles2010/DOLNorthw estWorkforce%20DevelopmentForum/WA%20State%20-%20Tool%20Kit.pdf 65

66. RESOURCES Youth CareerConnect Community of Practice (temporary location): This site contains resource information for the YCC program including guides, handouts, recorded webinars, videos, research documents, and data, https://etagrantees.workforce3one.org/page/resources/1001422629124768152 https://etagrantees.workforce3one.org/page/resources/1001422629124768152 Youth Career Connect SGA http://www.doleta.gov/ycc/pdf/Youth_Career_Connect_SGA_13-01.pdf Youth.gov “Map My Community” allows users to search for federally-funded, youth related resources. The interactive mapping tool on this page to locate federally supported youth programs in your community. Search by full address or ZIP code and click Find Programs. If programs are found the location is marked on the map, http://youth.gov/map- my-community.http://youth.gov/map- my-community YouthBuild Counseling and Case Management Handbook (2010) focuses on how to offer the personal supports students need to overcome obstacles to achieving their goals, how to assist them in linking with the resources they need, and to document outcomes associated with the delivery of these services and opportunities to YouthBuild participants. The second part of the manual focuses on Case Management in Practice, http://youthbuild.workforcegps.org/~/media/WorkforceGPS/youthbuild/Files/Program%20H andbooks/Counseling_Case_Management_0610.pdf http://youthbuild.workforcegps.org/~/media/WorkforceGPS/youthbuild/Files/Program%20H andbooks/Counseling_Case_Management_0610.pdf 66

67. CONTACT US U.S. Department of Labor Employment and Training Administration 200 Constitution Avenue, NW, Room N-4456 Washington, DC 20210 Email: ycc@dol.govycc@dol.gov 67