MCWDB MONITORING OVERSIGHT POLICY.PDF

SUBJECT: Monitoring & Oversight Policy PAGE 1 OF 8
SECTION/REFERENCE: POLICY NUMBER:
ORIGINAL ISSUE DATE: REVISION DATE:
May 13, 2021
MARICOPA COUNTY AUTHORIZED BY: Maricopa County Workforce Development Board
WORKFORCE DEVELOPMENT BOARD
SUBJECT: Monitoring & Oversight Policy ADDENDA:
Purpose: To provide oversight of program and financial activities through monitoring and technical assistance in
compliance with federal and state and county requirements.
Background: The Maricopa County Workforce Development Board (MCWDB) has a responsibility to provide
oversight and monitoring of programs and activities supported with funds that flow through the local area’s fiscal
agent. This policy is intended to ensure compliance with the Workforce Innovation and Opportunity Act (WIOA)
and all state and local requirements while at the same time, providing guidance for continuous improvement and
technical assistance.
The MCWDB is committed to ensuring compliance with Sections 183, 184 and 185 of the Workforce Innovation
and Opportunity Act; 20 CFR Part 683; 29 CFR Parts 95 and 97, Uniform Administrative Requirements; 2 CFR Part
200; appropriate OMB Circulars and requirements. Oversight includes review of administrative and fiscal
requirements, as well as program performance to ensure that the programs achieve intended results, and that
grant funds and other assets are adequately safeguarded.
Who should read this Policy: Maricopa County Workforce Development Board (MCWDB), its staff, grantees and
their staff, sub-grantees, or other entities providing program services funded through the MCWDB.
Policy
Responsibilities: The MCWDB’s oversight responsibilities of the ARIZONA@WORK-Maricopa County System
include, but are not limited to, the following:
Administrative Oversight
1. Compliance with the Shared Governance Agreement as assessed by OEO and DERS
2. One-Stop Center certification
3. Organizational structure
4. Administrative policies and procedures
5. Grievance procedures
6. EEO procedures
7. Subrecipient capacity to provide oversight
8. Americans with Disabilities Act (ADA) compliance
9. Non-discrimination and civil rights provisions
10. Equal opportunity requirements
Program Oversight
Program and special population oversight will be conducted pursuant to the Methods of Oversight as detailed in
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this document.
1. WIOA Title I-B Adult, Dislocated Worker, and Youth programs management and standards
2. WIOA Title I-B Adult, Dislocated Worker, and Youth programs policies and procedures
3. WIOA Title I-B Adult, Dislocated Worker and Youth Programs goals and objectives
4. Service delivery under the WIOA Title I-B Adult, Dislocated Worker and Youth programs and WIOA Title I-B
Adult and Dislocated Worker Program programmatic such as basic career, individualized career services,
and training services, including occupational skills training, Individual Training Accounts, and work-based
training activities, such On-the-Job Training, Customize Training, and Incumbent Worker Training, Eligible
Training Provider List, and Business Services
5. WIOA Title I-B Youth Programmatic areas such as design framework services, and the 14 program
elements;
6. Access to WIOA Title I-B Adult, Dislocated Worker and Youth services
7. Participant eligibility for the WIOA Title I-B Adult, Dislocated Worker, and Youth Programs;
8. An examination of actual expenditures against the cost categories and cost limitations
9. WIOA Title I-B Performance measures and program outcomes (actual versus planned)
10. Services to priority and special populations
11. Record retention and case file maintenance
12. Subrecipient monitoring activities
13. Supportive services and needs-related payments
14. Data analysis
15. Data element validation
16. Self-monitoring activities
Fiscal Oversight – All WIOA transactions
All Fiscal activities and oversight related to WIOA transactions shall with comply with the Uniform Administrative
Requirement (2 CFR Part 200) along with all rules, requirements, and regulations of WIOA. In addition, fiscal
activities and oversight shall adhere to Maricopa County established policies, procedures, and requirements,
including but not limited to the Maricopa County Grant Manual, Maricopa County Internal Policy on Administering
Grants, and the Maricopa County Procurement Guide. These documents outline how each of the following are to
be carried out, if not already detailed below. The fiscal agent and MCWDB staff are expected to follow these as
well as an internal procedures and policies as they set forth to ensure compliance in WIOA transactions.
1. Accounting and reporting systems- The system of recorded shall be the Maricopa County financial system,
CGI.
2. Fiscal agent responsibilities and activities- These shall be adhered to as outlined in the Shared Governance
Agreement.
3. Fiscal policies and procedures
4. Fiscal plans and agreements
5. Subrecipient monitoring activities
6. Cost allocation and allowability
7. Resource sharing
8. Budget Methodologies
9. Cash management practices
10. Cash disbursement compliance and documentation
11. Internal controls
12. Reporting requirements- All DES reporting requirements shall be adhered to.
13. Closeout procedures
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14. Audits
15. Subcontract compliance
16. Program income and reporting
17. Property management – Maricopa County policy A1901 Leasing or Licensing of Real Property from Public
or Private Entities shall be adhered to.
18. Record retention – Records retention policy of WIOA and Maricopa County shall be followed.
19. Generally Accepted Accounting Principles (GAAP) adherence
20. Payroll administration – This is managed by the Fiscal Agent, and other entities Maricopa County,
including Human Resources. County policy HR2418 shall be followed.
21. Insurance coverage and risk exposure – Maricopa County is self-insured, and as acceptance of the funds is
by the Board of Supervisors, Maricopa County local Workforce Area is covered by the BOS through:
a. Declaration of Trust for Self-Insured Risk Trust Fund (PDF)
b. Funding and Payment of Workers' Compensation Claims - A2223
c. Self-Insured Property Coverage and Deductible Policy - A2230
d. Policy A2234a - Injury and Illness Prevention Plan
22. Purchasing and procurement processes and procedures (as applicable
Other
1. At the discretion of the MCWDB, specialized oversight activities may be authorized to investigate
allegations of mismanagement, to clarify unusual findings, or to document current conditions. This
includes the Maricopa County Internal Audit Office and/or the fiscal agent depending on the nature of the
activities. The additional oversight will be in conjunction with the MCWDB staff.
Methods of Oversight
To ensure compliance with the WIOA and Federal Regulations, the MCWDB shall annually review each contract
during the Program Year . Desk reviews will also be conducted periodically as appropriate.. The following activities
may be utilized in the local oversight process:
1. On-Site Visit: The MCWDB through its staff or hired contractors will perform fiscal and programmatic
monitoring to ensure all funds allocated to the local workforce development area are adequately
safeguarded, program performance levels are met, and local subcontractors are programmatically,
operationally, and fiscally compliant.
There may be times when a contract is entered into where only a small number of customers (5 or less)
are involved in the training. In such cases, it may not be practical or cost effective to conduct an on-site
monitoring visit. Therefore, desk monitoring (see below) may be used on a limited basis for contracts of
this type. The following are the criteria that must be met for desk monitoring/review to occur:
A. Contract is for five (5) or less customers;
B. The total cost of the contract does not exceed $25,000.00
C. Adequate documentation is obtained and maintained in the permanent monitoring file to
document:
1) Eligibility- both programmatically and for training services;
2) Time and/or attendance reports;
3) Progress reports to document that customer has not dropped out;
4) Existence of an Individual Training Account Plan
5) Record of completion of training/credit hours earned/passed;
6) License or certificate;
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7) Placement and wage information, where applicable;
8) Financial records (e.g. invoices for payments, amount of Pell Grant where applicable;
and
9) Adequate documentation to insure accuracy of information.
D. There are no known problems with the contractor operations that would warrant
an on-site visit; and
E. The MCWDB has determined and documented that desk monitoring is the most
practical means of monitoring the service providers/contractor.
In all cases, desk monitoring/review is to be the exception and not the rule.
2. Desk Review: The MCWDB may perform desk reviews of the WIOA Title I-B programs and related
financial and participant data to ensure compliance, to identify potential or recurring problems to prepare
for more in-depth on-site visits, and to conduct more systematic and continuous oversight.
3. Random Sampling: The MCWDB may select a pre-defined volume of samples at random to be used to
help identify compliance violations, questioned costs, and/or potential weaknesses in performance.
Note: All WIOA Title I-B participant data and any other data that contains Personally Identifiable
Information (PII) must be handled per the MCWDB Personally Identifiable
Information Policy.
4. Surveys: The MCWDB may use surveys to help identify compliance violations, questioned costs, or
potential weaknesses in performance, as well as to capture promising practices or the need for technical
assistance.
Oversight Resources
The MCWDB will use the following resources to meet their responsibility for oversight and monitoring of
program and activities:
1. Monitoring Instrument/Questionnaire(s): The MCWDB has developed written oversight tools to assist
in conducting thorough review of WIOA Title I-B programs and activities, taking into consideration the
varying requirements of each of the funding streams. The monitoring tool includes at a minimum:
a) Name of the agency
b) Name of the individual performing the monitoring
c) Date of the monitoring
d) Services or activities provided
e) Total amount of the contract and sources of the funding
f) Date(s) of the oversight activity
g) Staff interviewed
h) Summary of the results that include program strengths, concerns, deficiencies, and areas where
technical assistance may be needed
2. Technical Assistance: The MCWDB through staff or contractors will provide technical assistance, as
needed, as a means of improving program operations, facilitating the implementation of corrective
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action, or providing information. Assistance may include but is not limited to: special training, discussion
of areas of concern, evaluation of program operation, or any combination thereof.
1. OVERSIGHT PROCESS
Activities
The MCWDB oversight activities will include monitoring and will assess the
subrecipient and contracted service provider’s compliance with federal, state, and local
laws, regulations, contract provisions/grant agreements, policies, and official directives and compliance
with the appropriate uniform administrative requirements for grants and agreements. Oversight activities
will encompass administrative requirements, fiscal, and programmatic monitoring. Depending on the
activity, the MCWDB staff and/or the Fiscal Agent shall establish and follow fiscal monitoring and
oversight procedures as aligned with the Fiscal Oversight section of this policy.
SCHEDULE
A monitoring schedule will be set and adopted by the board annually. The schedule will list, at a
minimum, Service Provider/Contractor names contract number & planned date(s) of review.
REVIEW NOTIFICATION
The MCWDB will provide advance notification to each of its Service Providers /Contractors prior to any
on-site review (preferably two weeks in advance of an on-site review).
MONITORING INSTRUMENT/QUESTIONNAIRE
A MCWDB monitoring instrument/questionnaire will be completed for each on-site visit. Procedures at
this level will include performance reviews to ensure that performance and customer data will be
collected and analyzed for all program activities included, but not limited to:
A. Administrative,
B. General compliance, and
C. Programmatic and fiscal compliance
ON-SITE REVIEW PROCESS
An on-site review is conducted by WCWDB staff or contractors and consists of:
A. An Entrance Conference to brief Service Provider/Contractor administrators/staff on the scope
of the review and to make appropriate arrangements;
B. A review of administrative, and programmatic systems and transactions;
C. Performance of test work, based on a review and examination of WIOA Title I_B records and/
or interviews, to determine if adequate internal controls and procedures are in place; and
D. An Exit Conference to apprise Service Provider/Contractor officials of probable Findings and
Areas of Concern.
DESK REVIEWS
Desk reviews of the participant files on the Arizona Job Connection System will be completed prior to the
onsite visit. All activities and documents required to be uploaded will be reviewed.
Reports & Resolution of Findings
After each review, all findings will be documented in writing and will include a description of the specific
non-compliance of federal or State laws, policies, regulations, and/or Grant Agreement. The detailed
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written report will note Findings and specify the Act, policy, regulation or contractual provision resulting
in the findings. Areas of Concern will include recommended corrective actions to be taken. Results from
any monitoring conducted will assist the MCWDB with strategic planning efforts, as this may identify
areas needing increased MCWDB focus. These reports can enable the MCWDB to assess program
contractor compliance, plan future technical assistance activities, and adjust policies to reflect emerging
economic opportunities. In addition, local monitoring reports will be made available for state and/or
federal review.
WORKING FILE
During the on-site review, a working file will be maintained. The working filewilldocument all tests
performed and all Findings. Findings will be documented in the final report. It will also contain other
documentation as deemed appropriate to substantiate that monitoring has occurred. Organization of the
file may be by systems reviewed, actual test work performed, or any other method deemed appropriate.
FORMAL MONITORING REPORT
After each review, a monitoring report will be prepared within 30 days from the date of the Exit
Conference detailing Findings and corrective actions, or to indicate that there are no Findings. Areas of
concern mustalso be indicate recommended corrective action to be taken. The following elements will be
included in the monitoring report:
A. An identification of all members who participated in the monitoring;
B. The dates of the review, program area(s), customers and service area(s) covered in the review;
C. A sequential listing of Findings and Areas of Concern, if applicable. Where Findings are noted,
each Finding shall consist of an objective narrative description of the non-compliance of federal or
State law, state-level WIOA Title I-B policy, MCWDB policy, regulation, and /or Grant Agreement;
and
D. Each Finding and/or Area of Concern is to be followed by a corrective action which sets forth
the most appropriate action to address any deficiency or non-compliance and propose a specific
time line for the corrective action to be completed.
FINDINGS
After each review, all Findings will be documented in writing and will include a description of the specific
non-compliance of federal or State laws, state-level WIOA Title I-B or MCWDB policies, and/or Grant
Agreement. The detailed report will note Finding and specify the statue, regulation, policy, or grant
agreement that has been noted as non-compliant. Each Finding will have a corresponding Required Action
that identifies what action must be taken or documentation providedand a timeline in order for a Finding
to be resolved.
The MCWDB monitor(s) will prepare a summary of findings following any monitoring conducted that is
presented for review through MCWDB committees. The respective MCWDB committee(s) will review and
provide recommendations to the full board for approval.
AREAS OF CONCERN
Areas of Concern are issues, policies, or practices observed during the review that negatively impact
effective contract management or provision of services to participants. They may also be areas that, if not
corrected, may lead to an area of non-compliance in the future.. Each Area of Concern must have a
corresponding recommendation for improving the issue/practice. Service Providers/Contractors are
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encouraged to implement the suggested action for improving/resolving the area of concern
issue/practice. If during the review, outcomes observed are sufficiently effective or innovative to warrant
“highlighting” in the report, they shoud be shared with other sub-recipients and contract service
providers.
CORRECTIVE ACTION PLAN
The Monitoring Report will be forwarded to the monitored Service Provider/Contractor via a transmittal
letter requiring a written response from the Service Providers/Contractors within 30 working days from
the day of report. The Service Provider monitored will be required to identify specific corrective action
measures to be implemented for each Finding and/or Areas of Concern identified. This Corrective Action
Plan must be submitted to the MCWDB monitor(s)
within thirty (30) days of the issuance of the Monitoring Report, or as requested in writing by the
MCWDB.
Upon receipt of the Service Provider’s Corrective Action Plan (CAP), the MCWDB monitor(s) will review
the response and in writing comment on the acceptability of the proposed corrective action. If the
corrective action is deemed acceptable, the monitor will recommend to the MCWDB Board or committee
that the Finding be deemedresolved. If the CAP or any part thereof is unacceptable, additional corrective
action is required. The Finding and/or Area of Concern will remain unresolved until it is approved.
FOLLOW-UP MONITORING AND VERIFICATION OF CORRECTIVE ACTION
Based on the CAP submitted, the MCWDB through staff or contractors will institute follow-up monitoring.
Follow-up activities will be conducted within 90 days of the date of the CAP approval as appropriate. A
copy of the completed monitoring tool used to conduct the oversight activity will be made available to the
monitored entity upon request. During the follow-up monitoring, the review will determine if the
corrective action measures and/or documentation were implemented to resolve the noted Finding(s).
Appeal Process
All final determinations may be appealed pursuant to the process according to §683.420 and the process
outlined in the MCWDB’s Local Monitoring Appeal Policy.
Access to Records
A The MCWDB, or its authorized representatives, has the right to access any records in a timely
manner consisting of books, documents, papers, computer records, emails, or other records or
Sub-Recipients and contract service providers that are relevant to the use of any WIOA Title I-B
funds administered by the MCWDB and may also make excerpts, transcripts, and photocopies of
documents as appropriate.
B. Right to access also includes timely access to personnel for interviews and discussions related
to reviewed documents.
C. Right to access is not limited to any required record retention but will last as long as records are
retained. Except as otherwise provided, records must be retained for at least three years from
date of exit. If any litigation, claim, negotiation, audit or other actions involving the records has
begun before the expiration of the 3-year period, the records must be retained until completion
of the action and resolution of all issues which arise from it, or until the end of the regular 3-year
period, whichever is later.
D. Right to access will also include any documents or staff of any service provider that no longer
retains their contract. At that point in time the MCWDB will review all files for any compliance
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SUBJECT: Monitoring & Oversight Policy PAGE 8 OF 8
issues. Any compliance issues found will be brought into compliance by that service provider
before final payment.
Monitoring Files
Monitoring files will be maintained by the MCWDB for at least 3 years after termination of service or a
provided by WIOA or county policies.. A separate file will be maintained for each on-site visit. At a
minimum, the file will contain the following records:
A. The letter announcing the monitoring visit; when an email is used to announce the monitoring
visit, a copy of that email shall be retained;
B. Completed pre-on-site planning documents;
C. Completed monitoring instrument/questionnaire(s);
D. Letter and transmitted Monitoring report to Service Provider/Contractor and, if applicable,
requiring a corrective action from the Service Provider/Contractor;
E. Letter to Service Provider/Contractor accepting/rejecting corrective action; and
F. Working papers to include actual test work performed and documentation to support finding(s)
and/or observations.
Service Provider Internal Monitoring
All MCWDB Service Providers, per theircontract terms, are expected to perform annual self-monitoring of
the customer and fiscal activities undertaken to ensure compliance with the act, CFR’s, OMB Circulars,
State regulation, state-level WIOA Title I-B policies, MCWDB policies and procedures, and Grant
Agreement provisions. The Service Provider must send the MCWDB a monitoring schedule within the first
quarter of its contract period; undertake carry-over client file monitoring within the first quarter;
undertake newly enrolled clients and fiscal expenditures no later than early in the third quarter of the
contract period; prepare and have available for review by the MCWDB reports regarding the self-
monitoring. Service Provider internal monitoring must be completed before the fourth quarter unless
specified separately in their contract.. This is to ensure that customer files and/or expenditures associated
with them have been resolved, and all contracted activities have been met.
2. REFERENCES
WIOA Section 183
20 CFR Part 683.410
OMB 2 CFR Part 200
3. HISTORY
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