Findings and Questioned Costs Relating to Federal Awards: Eligibility of Individuals, Allowable Costs DDEC is implementing a series of corrective actions to ensure full compliance with WIOA eligibility documentation requirements, internal controls, and participant file management. The primary correc...
Findings and Questioned Costs Relating to Federal Awards: Eligibility of Individuals, Allowable Costs DDEC is implementing a series of corrective actions to ensure full compliance with WIOA eligibility documentation requirements, internal controls, and participant file management. The primary corrective strategy is the establishment of the PRIS system as the official digital participant file, combined with strengthened internal controls, mandatory documentation requirements, system validations, staff training, and ongoing monitoring. These corrective actions are designed to ensure that: • Eligibility documentation is completed and verified before services are provided. • Costs are only charged to WIOA programs for eligible participants. • Internal controls comply with 2 CFR 200 requirements. • Monitoring and validation processes ensure long-term compliance and sustainability. 1.Official Digital Participant File (PRIS) DDEC will designate the PRIS system as the official participant file repository for all WIOA programs. Services may not be recorded, and costs may not be charged unless the participant’s digital file contains complete eligibility documentation and a signed eligibility certification. Key Actions: • Issue formal directive establishing PRIS as the official file system. • Update operational manuals and program guidance. • Notify all subrecipients of implementation requirements. 2. Required Eligibility Documentation Controls DDEC will require that all eligibility documentation be uploaded to PRIS before participant activation or service entry. Required documentation includes proof of age, work authorization or citizenship, Selective Service registration (if applicable), proof of residence (if applicable), and signed eligibility certification. Key Actions: • Establish mandatory documentation checklist by participant type. • Require digital upload of all eligibility documentation. • Establish document quality and digital format standards. 3. PRIS System Controls and Validations DDEC will implement system controls within PRIS to prevent the entry of services or costs for participants with incomplete eligibility documentation. Key Actions: • Configure required fields for eligibility documentation. • Develop exception reports for incomplete participant files. • Pilot system controls with one subrecipient prior to full implementation. 4. Internal Controls and Monitoring DDEC will strengthen internal controls to ensure that eligibility documentation is verified prior to service delivery and cost charging. Key Actions: • Monthly PRIS exception reports identifying incomplete files. • Required correction within established timeframe. • Suspension of services or payments for non-compliant files. • Integration of digital file review into monitoring visits. • Standardized eligibility checklist for all subrecipients. 5. Training and Technical Assistance DDEC will provide training to subrecipients and internal staff on WIOA eligibility requirements, documentation standards, PRIS usage, and federal compliance requirements under Uniform Guidance (2 CFR 200). Training Topics: • WIOA eligibility requirements • Acceptable documentation • PRIS document upload procedures • Allowable costs and federal compliance • Internal control responsibilities 6. Ongoing Monitoring and Compliance Validation DDEC will implement quarterly compliance validation through sampling of participant files in PRIS to ensure documentation completeness and sustained compliance. Monitoring Measures: • Quarterly file sampling by subrecipient • Documentation completeness verification • Corrective action plans for subrecipients with deficiencies • Escalation procedures for repeated non-compliance • Annual compliance review after full implementation