AC-1 Question: A-C made assumptions on policies which were not clearly defined. In response to this, LA County created policies such as ’due diligence’ which created a challenge to serve people with barriers.
EDD is reviewing all areas of LA Co’s operations, which includes looking at the WSCs and the A-C’s responsibility is to ensure that the Programs are being administered according to Program regulations. In preparation for the review, the A-C completed its monitoring of the WSCs and provided CSS with its findings. These findings were an indication of systemic issues concerning client file documentation. CSS used these results to request WSCs to conduct a quality control check of its client files to ensure compliance with mandated guidelines.
AC-2 Question: A-C found missing documentation while conducting monitoring reviews of the SYEP for all WSCs and did not provide the WSC the opportunity to provide proper documentation to address the findings at the time of review.
AC’s Response: We met with each contractor’s management personnel on a daily basis during the course of the review. We notified management staff of our preliminary findings on a daily basis. We told them which documentations were missing as we found discrepancies. We told them what we would need to clear the findings during the course of our review. And yet, they didn’t provide the documentation we requested.
On the last day of fieldwork, we held a preliminary exit meeting in which, again, we discussed our findings with Agency’s management in great length and detail. At the preliminary exit meeting, we also provided the Agency’s management with a listing of our findings. We even had their management personnel sign off on the listing of findings to indicate that the findings were discussed with them during the preliminary exit meeting. Any documentation provide during the preliminary exit meeting were accepted.
We felt that we provided more than adequate number of opportunities for the WSC to provide proper documentation to address the findings at the time of review.
AC-3 Question: How was the A-C’s review conducted?
The A-C’s review was conducted as follows:
- A-C reviewed a sample of client files. A-C provided the results of its review (i.e., findings) to the contractors; even prior to providing the results to CSS.
- CSS reviewed the findings and noted that these issues were systemic.
- In response, CSS released a directive addressing the due diligence policy, which was issued to contractors in draft form.
CSS has issued letters to those Contractors with findings and Contractors shall respond by Thursday, January 21, 2010.
AC-4 Question: There is a concern that findings (and disallowed costs) were noted by A-C during its review in cases where documentation was not in the client file(s) as of the time of enrollment but were subsequently provided to A-C upon its request.
When a client is enrolled in the Program, the client’s enrollment documentation should be completed and filed at that time. The enrollment documentation should not be completed after the client has begun Program services.
C-1 Question: There are 2 issues: 1.) There was a publication of results without the opportunity to resolve problems; and, 2.) The 100% Review will be conducted on SYEP and this Program is over; there is no staff and the funds have been used. What funds should be used by the contractors to pay for this review?
The costs and funding for this 100% Review are some of the potential issues that LA Co. will be considering.
C-2 Question: What does LA Co. and the WSCs need to do to move forward?
The 100% file review should be conducted with those WSCs which have been classified as ‘high risk’; the low-risk WSCs should be excluded from this review.
C-3 Question: (By: CSS): Form I-9 Requirement for SYEP 100% Review
- The Form I-9 is included in the monitoring review checklist.
- WSCs shall ensure that documentation meeting Form I-9 requirements is included in each client’s file.
E-1 Question: Eligibility is a snap shot at the time of enrollment. Documents can be obtained to prove that at the time the snap shot is taken these clients were eligible; however, it is considered a disallowed cost which is unfair. For example, in the case of a homeless client at the time of enrollment the applicant statement was not in the file.
If the applicant statement was not in the file as of enrollment, based on the Due Diligence Policy, this client is not eligible as required by the Policy. The Policy was developed to provide guidelines on appropriately determining and documenting client eligibility.
E-2 Question: At the Auditor Controller Common Findings training meeting on April 1, the AC staff said all social security cards need to be signed unless there is an age or health issue. We had a client who brought in the attached card. It says youth should not sign until they are 18 or their first job, whichever is earlier. Please clarify for us.
Upon review of the social security cards, it appears that the cards do not need to be signed by an applicant or family members until the individuals reach the age of 18 years old or begin their first job. The requirement for signatures on the social security cards will now mirror that policy indicated by the Social Security Administration. This revision will be incorporated in the TAG on page 55 under “Note: A social security card is invalid if not signed by the number holder unless health or age prevent signature.” In the situation above, it is age that would prevent signature. Therefore, any findings related to an unsigned social security card that falls within this parameter will be waived.
E-3 Question: Due Diligence Policy. The policy states the “new requirement is that the form must contain a management review and signature before the youth is deemed eligible”. We changed our form to add this requirement. Yet the form used at the meeting did not contain this requirement. If it is not required, please let us know because this new level of review takes more time which slows down the eligibility determination process.
According to the ARRA/WIAD 09-22 Directive on page 5, under Requirements and Prohibitions, # 9, it indicates, “WIA contractor staff must indicate what eligibility criteria the applicant statement is being utilized for and sign and date the document.” In addition, on page 6, under Procedures, # 4, it indicates, “Requiring management level review of participant files to ensure both the appropriate use of the applicant statement and the due diligence in being performed correctly.” The latter reflects policy in affect pertaining to quality assurance but does not require that management sign off as documentation of due diligence.
Furthermore, the Directive does not dictate the format or frequency of the review. This review is to assist line-staff and provide them guidance on the appropriate use of the Applicant Statement.
E-4 Question: We have groups of youth being referred for WIA Youth Services and we need confirmation of whether they are considered In-School or Out of School
- The Youth are currently attending a transitional high school program for Special
- The Youth have received a Certificate of Completion, but not a high school diploma or its equivalent
- The Youth are Basic Skills deficient
Part 1): Our understanding from the TAG is that because they have not received a diploma, but just the Certificate of Completion, they are considered In-School youth. Is this correct?
Does the County see the Certificate of Completion as the equivalent to a Diploma?
Answer Question 1:
It is important to review the definition of Out-of-School Youth.
The definition below is from TEGL 1705, ATTACHMENT B: DEFINITIONS OF KEY TERMS.
The Definition of Out-of-School Youth – An eligible youth who is a school dropout, or who has received a secondary school diploma or its equivalent but, is basic skills deficient, unemployed, or underemployed (WIA section 101(33)). For reporting purposes, this term includes all youth except: (i) those who are attending any school and have not received a secondary school diploma or its recognized equivalent, or (ii) those who are attending post-secondary school and are not basic skills deficient.
Yes, as these youth are attending school and do not have a secondary school diploma or its recognized equivalent, they are in-school-youth.
Answer Question 2:
Per the State of California, Department of Education, beginning with the Class of 2006, all public school students will be required to pass the California High School Exit Examination (CAHSEE) to earn a high school diploma. Per California Educational Code Section 56390 , if a student with disabilities does not meet all state and local requirements for earning a high school diploma, including passing the CAHSEE, then the local educational agency may award the student a certificate of completion.
No, per California Educational Code Section 56391, a certificate of completion is not the equivalent of a diploma.
F-1 Question: How much of a cash float will be allowed? When will the float start?
There is a 3 day cash float and the Cash Management System has been established to address all issues and expectations. The Cash Management System will enhance the services provided by Contractors and Sub-contractors.
F-2 Question: The Cash Management System should provide broader control and allow more flexibility on line item categories reflected on the Program budget for items such as rent, supplies, etc. (i.e., WSCs should be given more flexibility to spend on budget line items such as rent, supplies, etc. such that fluctuations in expenditures within each line item are allowable as long as the total budget amount is not exceeded).
There will be a process to streamline and establish flexibility and control on each individual budget line item.
P-1 Question: What are some recommendations to improve the partnership between LA Co. and WSCs.?
- Make the JTA system more user-friendly so that additional barriers aren’t created in the process of helping clients.
- CSS’ administrative services divisions should provide more technical assistance to WSCs.
- CSS and A-C should provide coordinated technical assistance for WSCs.
- CSS should work with A-C to address and resolve the A-C’s monitoring findings.
- CSS should review the findings noted for each of the WSCs. CSS should schedule a meeting with all the ‘high-risk’ contractors by next week.
- CSS will work with those contractors who received disallowed cost letters to resolve these issues.
- Recommend A-C review a sample of cases at random; WSCs will be afforded ample time to prepare for this review.
- For the 47 Files with disallowed costs: CSS will issue a closure letter to WSCs when CSS has verified that client eligibility has been established and documented.
P-2 Question: Where and why should WSCs submit stories, comments, information on client success stories, forecasts, etc.?
All the information provided to Linda Tarnoff via email at LTarnoff@css.lacounty.gov will be used to prepare the 10th Annual Report used by the WIB to represent activities from LA Co.
P-3 Question: According to the WIA TAG on page 39, a self statement must be used every time an applicant claims little or no income for the past 6 months or claims to be no longer dependent. However the Directive issued on 12/17/09 (Due diligence requirement s for use of applicant statements) page 6 indicates contractor’s frequent and consistent use of applicant statements may raise concerns during program monitoring. The policy established in the WIA TAG page 39 states we must use a self statement to document these eligibility items. We have not been given any other option to document little or no income/no longer dependent other than a self statement. So our question is this… Should we continue to use a self statement for every applicant who claims little or no income/no longer dependent according to the local policy established on page 39 of the WIA TAG 10/08?
The statement that was cited in your question refers to a very specific targeted group which has been highlighted as such with a box drawn around the criteria as a local policy. Thus, this is a unique population.
These individuals must have all of the following criteria, as outlined on page 39 of the TAG:
- an older youth
- not full time student in a secondary school (High school) or equitant
- living in a single resident with their parents(s) or guardian(s).
The actual policy is to assist in the determination of dependency status as to which income documents need to be reflected in the calculations.
The policy allows for a statement when the individual claims little or no income. It is important to note that your agencies staff has the task of surfacing what income most accurately reflect the individual’s actual situation and do not conflict with other documentation that is present in the file.
In regard to the reference made to Directive ARRA/WIA D09-22, page 6, Concerns that May Arise from the Use of Applicant Statements, the first two sentences are applicable and relevant to your point. They read as follows: “Contractors’ frequent and consistent use of applicant statements may arise concerns during program monitoring. Such concerns may arise when the applicant statement is an agency’s standard procedure for all applicants to document one or more eligibility, such as family size.” All is the key wording here. As stated above, your question pertains to a specific targeted group.
As pertains to the situation above, the use of the applicant statement for individual who claim little or no income is allowed.
JTA / MIS
WIA Accomplishments-WorkSource and Youth Centers, June 7, 2010
In Kind Training Webinar QA, July 15, 2010.pdf
ECF Inkind Training (2).pdf