Finding Text
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.