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PROGRAM PROGRAM MANAGEMENT AND MANAGEMENT AND ACCOUNTABILITYACCOUNTABILITY
Requirements and Considerations Requirements and Considerations Across Discretionary GranteesAcross Discretionary Grantees
Day One Plenary Session—Presentation Day One Plenary Session—Presentation
Accountability and Grants Management:Connecting the Dots
U.S. Department of Labor, ETA, Region 4 U.S. Department of Labor, ETA, Region 4 Discretionary Grantee Training ConferenceDiscretionary Grantee Training Conference
March 1-2, 2011March 1-2, 2011 11
ObjectivesObjectives
Establish a foundation for program management and related accountability requirements, irrespective of the source of the requirements or the employment and training program funded
Identify gaps in current plans, policies or operations and discuss ways to address
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Approach (1)Approach (1)
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Approach (2)Approach (2)
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ConsiderationsConsiderationsAs You Develop Your Accountability Framework…As You Develop Your Accountability Framework…
Definitions—Don’t believe everything you think (a/k/a Webster’s dictionary doesn’t always apply)
Make sure you’re following all required parameters
You need systems to capture, maintain, and report all the information Policies, Procedures, Protocols
When there are partners, sub-awards, contractors . . .
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Who you’re serving…Who you’re serving…General Grantee Requirements*General Grantee Requirements*
All grantees need policies and procedures to ensure compliance with all federal parameters governing who can participate in the program
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*Although this section applies to grantees serving participants, policies and procedures to support operations is critical across
grantees and organizations.
Who you’re serving…Who you’re serving…Federal ParametersFederal Parameters
Citizenship Selective Service Veteran Status Ethnicity, Race, Disability Status SSN Characteristics (grant-specific although
many are common such as socioeconomic data, age, employment status at entry, level of education)
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Who you’re serving…Who you’re serving…Data Sources and DocumentationData Sources and Documentation
Sometimes have same meaning / not always
Sometimes specified, or minimum requirements provided with details left up to grantees
Some grantees assume “documentation requirements” that don’t exist
What does your _________ say? What does your _________ say?
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Who you’re serving…Who you’re serving…Citizenship RequirementsCitizenship Requirements
“Participation in programs and activities … shall be available to citizens and nationals of the United States, lawfully admitted permanent resident aliens, refugees, asylees, and parolees, and other immigrants authorized … to work in the United States.” WIA, Sec. 188(a)(5)
Documentation could include _________________ or ___________________ (formerly “________ card”)
Do you currently capture this information? How?
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Who you’re serving…Who you’re serving…Selective Service RequirementsSelective Service Requirements
“The Secretary shall ensure that each individual participating in any program or activity… has not violated section 3 of the Military Selective Service Act (50 U.S.C. App. 453) by not presenting and submitting to registration as required…” WIA, Sec. 189(h)
Registration required for all males born on or after 1/1/60 within 30 days of 18th birthday with late registrations accepted until age 26
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Who you’re serving…Who you’re serving…Selective Service Requirements (2)Selective Service Requirements (2)
From www.sss.gov –
“Some men may have failed to register during the time they were eligible to do so and may now find they are ineligible for certain benefits.”
“The Workforce Investment Act (WIA)…. is only open to those men who register with Selective Service.”
Documentation could include __________________ ___________________ noting the person registered
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See Handout #1
Who you’re serving…Who you’re serving…Veterans’ Priority of Service RequirementsVeterans’ Priority of Service Requirements
“Grantees are required to provide priority of services for veterans and eligible spouses pursuant to 20 CFR part 1010, the regulations implementing priority of service for veterans and eligible spouses in [DOL] job training programs under the Jobs for Veterans Act…” Text from an SGA (ETA policies also referenced)
“New” policy – Training & Employment Notice (TEN) 15-10 dated 11/10/10 contains implementation protocol
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See Handout #2
Who you’re serving…Who you’re serving…Veterans’ Priority of Service Requirements (2)Veterans’ Priority of Service Requirements (2)
Basically, __________ has to be eligible and, of those, “veterans and eligible spouses” receive priority
______ grantees must collect veterans’ characteristics and information to determine if priority of service (POS) applies
Documentation could include letter from veterans’ organization
______________ ok until documentation received
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Who you’re serving…Who you’re serving…Non-Discrimination / Equal OpportunityNon-Discrimination / Equal Opportunity
Grantees must collect information on Ethnicity, Race, Sex, Age, Disability Status Requirements appear in many places including 29 CFR Part
37, Civil Rights Act of 1964, etc. Purpose of mandatory data collection is to ensure equal
opportunity
Data collected on participants and applicants You have to ask but they don’t have to tell Are your forms properly designed?
Documentation __________________ unless otherwise stated since info is based on __________ ____________
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See Handout #3
Who you’re serving…Who you’re serving…SSNsSSNs
Collecting SSNs is usually required through the SGA and/or reporting instructions
Example: “Applicants will be required to collect participants’ Social Security numbers as part of individual level data collection…. Applicants must ensure that Social Security numbers will be maintained in a secure and confidential manner.” (ARRA HGEI 6/24/09 SGA)
Needed to calculate common measure outcomes
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Who you’re serving…Who you’re serving…SSNs (2)SSNs (2)
Individuals cannot be ____________ ____________ for failure to provide a SSN
Documentation could include ________ _________ _________ or military ID
Do any of your policies or procedures [even
unintentionally] require a SSN?
Do your intake forms/documents unintentionally discourage the provision of SSNs?
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See Handout #4
Who you’re serving…Who you’re serving…Characteristics Characteristics
Could include: Age Dropout status LEP Ex-offender Economically disadvantaged
Documentation can be specified in SGA and reporting instructions if populations are targeted Or sometimes a statutory reference is implied (e.g., WIA
defines adult as 18+, a target for CBJT grantees)
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See Handout #5
Who you’re serving…Who you’re serving…‘Housing’ Considerations for the Data‘Housing’ Considerations for the Data
“An applicant must collect and report participant-level data from the following categories: Demographic and socioeconomic characteristics; Services provided; and Outcomes achieved.” This text is in every SGA involving the
enrollment of participants
So what should grantees do with all the data that’s collected?
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Who you’re serving…Who you’re serving…‘Housing’ Considerations for the Data (2)‘Housing’ Considerations for the Data (2)
Participant data should live in both case files and the MIS Establish policy, procedures, protocols for
case files (e.g., __________?) Case files serve as a repository for information
and should be an ______________ of your MIS Example: Case file contains copy of certificate
whereas MIS just notes certificate was attained
Note: Grantees submit reports containing aggregate numbers but they’re based on ___________ ___________
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Who you’re serving…Who you’re serving…Connecting the DotsConnecting the Dots
Do you have a written eligibility policy, associated forms (e.g., consent forms, intake forms) and protocols in place (especially if there are subs) that incorporate all of the foregoing?
Are there gaps that could lead to compliance issues?
Where are there opportunities for improvement or refinement?
Would you be comfortable with a monitoring visit from your FPO next week?
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Sample/Handout #4
What they’re getting…What they’re getting…General Grantee RequirementsGeneral Grantee Requirements
Grantees are responsible for program design and delivery—including the design and delivery of services—within federal parameters that are general as well as those that are grant-specific.
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What they’re getting…What they’re getting…Federal ParametersFederal Parameters
Participants Only
Services (and/or Deliverables)
Scope, Complexity ranges across grantees
Terms / Definitions
Management of / Coordination with subs, providers, partners
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What they’re getting…What they’re getting…Data Sources and DocumentationData Sources and Documentation
“The applicant must collect participant-level data on . . . employment training and other services provided through the grant.”
Text from an SGA
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What they’re getting…What they’re getting…Participants OnlyParticipants Only
Participant—Individual determined eligible to participate in the program and who receives a service funded by the program (TEGL 17-05)
‘Qualifying’ Services – Know the services that trigger participation
Example: Eligibility determination by itself does not trigger participation
Participation Date = Date of _________ __________
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What they’re getting…What they’re getting…Scope/Complexity of ServicesScope/Complexity of Services
Generally speaking, the more complex the scope or range of services, the more “controls” you need
Key Consideration – Systems Needed
Would the decision-making process be easier, more fair, and/or more consistent if we had a policy in place?
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What they’re getting…What they’re getting…Scope/Complexity of Services (2)Scope/Complexity of Services (2)
Policies – Administrative tools describing what has to be done/why to help staff attain organizational goals
Procedures – Actions comprising the acceptable manner of performance so policies are consistently implemented
Steps 1—Define the issue, task, problem; 2—Determine
responsibility for development; 3—Develop draft using agreed-upon template; 4—Review/revise/make final; 5—Adopt/approve; 6—Implementation (distribution and education); 7—Regular review (eventual archival)
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What they’re getting…What they’re getting…Service Terms/DefinitionsService Terms/Definitions
Sometimes, services that are allowable are specified as unallowable in the SGA
Remember that Webster’s dictionary is not always applicable
Example: “Received Education or Job Training Activities” means something different for CBJT grantees, HGEI grantees, and YouthBuild grantees
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What they’re getting…What they’re getting…Management/Coordination CriticalManagement/Coordination Critical
Generally speaking, the more complex the arrangement of partners, subs, providers, the more ____________ you need
Key Consideration – __________ NeededNavigating relationships is hard under any
circumstances (add distance, varied experience, different understandings, existing “controls”)
If you don’t say what you mean, people will interpret it for you
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What they’re getting…What they’re getting…Connecting the DotsConnecting the Dots
Do you have a ‘participant flowchart’ or similar service design/delivery framework? Are the services provided consistent with the SOW (e.g., sequence, definitions, parameters)? Are protocols in place (especially if there are subs) that incorporate all of the foregoing? Are there gaps that could lead to compliance
issues? Where are there opportunities for improvement or
refinement? Would you be comfortable with a monitoring visit
from your FPO next week?
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With what results…With what results…General Grantee RequirementsGeneral Grantee Requirements
All grantees need a management information system that, at a minimum, captures required data, performs necessary calculations, and reports information needed to manage the grant and meet federal reporting requirements.
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With what results…With what results…Federal ParametersFederal Parameters
Exiters Exit vs. Completion Outcomes
Terminology; Common Measures; Other Measures
Unexpected Circumstances Gap in Service; Performance Exclusions
Quarterly Program Reporting Management of / Coordination with subs,
providers, partners
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With what results…With what results…Data Sources and DocumentationData Sources and Documentation
“An applicant must collect and report participant-level data [including] outcomes achieved.”
“Selected applicants will have to include projections and track such information as ‘total number of participants who complete employment and training activities that receive a degree, certificate, or other type of credential’.”
Typical text (generally within the same SGA)
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With what results…With what results…ExitersExiters
Exiter – A participant who hasn’t received a program or partner-funded service for 90 consecutive days and is not scheduled for future services (TEGL 17-05)
Exit Date is applied retroactively* to the last date of service (after 90 days of no service)
Exit Date = Date of ________ _________
Exit must be understood by all grantees Represents a trigger (e.g., inclusion in
common measure outcomes, beginning of youth follow-up)
33*Exception for YouthBuild grantees
With what results…With what results…Exit vs. Completion Exit vs. Completion
Exit is defined for you; Completion is usually defined within general parameters (grantees add the meat)
Completion often means successful completion
Everyone exits but not everyone completes (see your program reporting instructions)
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With what results…With what results…Outcomes—TERMINOLOGY Outcomes—TERMINOLOGY
If it’s not clear, get clarity! You’re accountable
“Completion”
The one-time-only nature of completion often presents challenges
Completion of entire program vs. completion of one ‘step’ or ‘course’
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With what results…With what results…Outcomes—TERMINOLOGY (2)Outcomes—TERMINOLOGY (2)
“Entered Employment” To be [the common measure] or not to be
Example: CBJTs and HGEIs are accountable for two different “entered employment” outcomes
Projected “Enrollments” Your projections were based on your
understanding of enrollment at the time you wrote the grant, which may not have been correct
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With what results…With what results…Outcomes—COMMON MEASURESOutcomes—COMMON MEASURES
All discretionary grantees are responsible for some common measure outcomes Adult Entered Employment Rate Adult Employment Retention Rate Adult Average Earnings Youth Placement in Employment/Education Youth Attainment of Certificate/Credential Youth Literacy/Numeracy
ALL calculations are based on the Exit Date with exception of Youth L/N
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With what results…With what results…Outcomes—OTHER MEASURESOutcomes—OTHER MEASURES
Note: Required program report formats will never fully account for what you have done with the funds you received!You could ‘stay within the box’
and still tell your story
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With what results…With what results…Unexpected Circumstances (1)Unexpected Circumstances (1)
[Slide #33 said Exit is based on 90 days of no service…] – With one exception
A participant should not be considered as exited if there is a gap in service greater than 90 days based on one of three circumstances:
1. Delay before beginning of training2. Health/medical condition of participant or family member3. Temporary move that prevents participation
Grantees need to understand federal parameters regarding gaps in service
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See Handout #6
With what results…With what results…Unexpected Circumstances (2)Unexpected Circumstances (2)
Certain conditions allow individuals to be excluded from common measure outcomes Institutionalization Health/Medical or Family Care Death Reservist Called to Active Duty Relocation to Residential or Non-Residential
Program (youth only) Exclusions apply if circumstance takes
place at exit or in the 3 quarters following
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With what results…With what results…Quarterly Program ReportingQuarterly Program Reporting
“Grantees must agree to meet DOL reporting requirements.” (SGA Text)
OMB-approved Program reporting requirements vary across
discretionary grantees Across grantees. . .
What Do FPOs Look For? General Suggestions About Data Quality
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What Do FPOs Look For?
1. _____________ – Reports due NLT 45 days after the end of the quarter (program and fiscal reports)
2. _____________ – All sections included, no pertinent information missing, referenced attachments are included
3. _____________ – cumulative numbers go up and not down, number of males and females equal total enrollments
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With what results…With what results…Quarterly Program Reporting (2)Quarterly Program Reporting (2)
General Suggestions Work on it _____________ the quarter Maintain easy access to your _______ As they occur, check off/crosswalk activities,
products, and deliverables to your SOW Keep list of events, meetings and activities you
would report to the leadership of your organization (e.g., college president)
Schedule time before the date to enter data, talk with staff, etc.
…and make sure your subs/partners do the same
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With what results…With what results…Quarterly Program Reporting (3)Quarterly Program Reporting (3)
About Data Quality Ensure data elements are well-__________ and
___________ by project staff (including contractors) Note: Original source of information is more reliable
than secondary information (e.g., info on ‘training completion’ from a community college should be used rather than second-hand info from participants through case managers)
Ensure duplication of effort does not occur in data collection (costly, lack of consistency)
Procedures needed (e.g., SOPs with timeframes and deadlines, responsibilities assigned)
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With what results…With what results…Quarterly Program Reporting (4)Quarterly Program Reporting (4)
With what results…With what results…Connecting the DotsConnecting the Dots
Do you have policies and procedures defining outcomes (ours and yours) and associated data elements and how the data are gathered, processed, reported (especially if there are subs) that incorporate all of the foregoing? Are there gaps that could lead to compliance
issues?
Where are there opportunities for improvement or refinement?
Would you be comfortable with a monitoring visit from your FPO next week?
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ConclusionConclusion
When you start connecting the dots you soon realize that, practically speaking, you cannot separate program design from program delivery, or either of those from program management, or any of those from program accountability. At least not without something important falling through the cracks.
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U.S. Department of Labor, ETA, Region 4 U.S. Department of Labor, ETA, Region 4 Discretionary Grantee Training ConferenceDiscretionary Grantee Training Conference
March 1-2, 2011March 1-2, 2011
Accountability & Grants Management: Connecting the Dots
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