Finding 1205249 (2025-001)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2025
Accepted
2026-03-31

AI Summary

  • Core Issue: The Local Area did not meet the required spending levels for Youth Program funds, using only 14% for work experiences and 38% for Out-of-School Youth services.
  • Impacted Requirements: Noncompliance with WIOA earmarking requirements, specifically the 20% for work experiences and 75% for Out-of-School Youth, despite a waiver allowing a lower threshold.
  • Recommended Follow-Up: Implement quarterly monitoring of earmark requirements involving finance and youth program staff to ensure compliance and address issues promptly.

Finding Text

FINDING REFERENCE NUMBER 2025-001 FEDERAL PROGRAM (ALN 17.258, 17.259 AND 17.278) WORKFORCE INNOVATION AND OPPORTUNITY ACT (WIOA) (CLUSTER) PASS-THROUGH – ECONOMIC DEVELOPMENT AND COMMERCE DEPARTMENT OF THE COMMONWEALTH OF PUERTO RICO U.S. DEPARTMENT OF LABOR AWARD NUMBER 2022-0000114 (FISCAL YEAR 2021-2022) COMPLIANCE REQUIREMENT MATCHING, LEVEL OF EFFORT, EARMARKING TYPE OF FINDING NONCOMPLIANCE AND SIGNIFICANT DEFICIENCY CRITERIA WIOA Youth Activities required that not less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences (Section 129(c)(4)), WIOA, 128 Stat. 1510). Also, a minimum of 75 percent of the Youth Activity funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to Out-of-School Youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). The DOL's Employment and Training Administration (ETA) approved a waiver for PY 2022 and PY 2023, which includes the entire time period for which states are authorized to spend those funds, the Puerto Rico Commonwealth's request to waive the requirement that local areas expend 75 percent of local youth formula funds on OSY. Puerto Rico may lower the local youth funds expenditure requirement to 50 percent for OSY. STATEMENT OF CONDITION During our audits test of the earmarking compliance requirement for the Youth Program funds of the program year 2023-2024, we noted that the Local Area only expended 14% of the funds allocated to programmatic activities on paid and unpaid work experiences at the end of the two years of funds availability which ended June 30, 2024. Also, the Local Area only expended 38% of the Youth Program funds allocated for program year 2023-2024 on services for Out-of-School. QUESTIONED COSTS None PERSPECTIVE INFORMATION This is a repeated finding and includes two earmarking requirements. This represents a systematic problem in our evaluation. STATEMENT OF CAUSE The Local Area failed to timely identify the lack of compliance with the earmarking requirement for the Youth Program and failed to planned activities for participants related to paid and unpaid work experience and activities for Out-of-School Youth during the two years of funds availability. POSSIBLE ASSERTED EFFECT The Local Area failed to comply with a programmatic requirement of the Youth Program. IDENTIFICATION OF REPEAT FINDING This is a Repeat Finding – Prior Year Finding Number 2024-001. RECOMMENDATIONS We recommend that a formal monitoring of the earmark requirements for the Youth Program, as well as other earmark requirements, takes place at least on a quarterly basis during the funds period of performance. Staff that should participate in the monitoring include finance, planning, youth program staff and executive staff. If deviations or failure to meet the earmark are noted, communications must be generated to the youth program staff in order to take corrective actions before the elapse of the funding period.

Corrective Action Plan

VIEWS OF RESPONSIBLE OFFICIALS Corrective Action Plan: • The Youth Committee of the Northwest Local Board will be composed of representatives from finance, Budget and Planning staff (Youth Program and Executive), who will measure compliance with 20% work experience expenditure requirement on a monthly and quarterly basis using updates financial reports. • An immediate review of current fund expenditure will be conducted to determine the exact percentage of compliance and to establish an accelerated spending plan, to ensure compliance with the 20%. • The committee will provide the Executive Director with recommendations to operation areas to meet required expenditure targets in accordance with section 20CFR 681.590, 684.00(a), and 681.600 of WIOA, including specific corrective actions when deviations are identified. • The Northwest Local Area will strengthen outreach strategies for youth program services through social media (Facebook, ticktock, Instagram) radio, television, and the official website, with the goal of increasing recruitment of eligible participants, particularly out of school youth. • Job Fair and Educational fairs for the Youth Program will be developed and implemented to recruit out-of-school youth and increase participation in work experience activities. • Efforts will continue through mass outreach campaigns with an effective strategic plan to expand the reach of the youth program, ensuring a measurable increase in enrollment and participation. • Ongoing monitoring with performance indicators will be implemented, including the percentage of expenditures on work experience and services to out-of-school Youth, with periodic reviews. • If necessary, technical assistance will be requested form the Youth Program Specialist of the Workforce Development Program (PDL) at the Department of Economic Development and Commerce (DDEC). IMPLEMENTATION DATE Immediately RESPONSIBLE PERSONS Executive Director, Finance Director, Youth Program Staff

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1205247 2025-001
    Material Weakness Repeat
  • 1205248 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $4.25M
17.258 WIOA ADULT PROGRAM $1.42M
17.259 WIOA YOUTH ACTIVITIES $1.31M