Finding 37141 (2022-001)

Significant Deficiency Repeat Finding
Requirement
G
Questioned Costs
-
Year
2022
Accepted
2023-03-12

AI Summary

  • Core Issue: The Local Area did not meet the required spending levels for paid work experiences (only 2%) and services for Out-of-School youth (only 22%) under WIOA guidelines.
  • Impacted Requirements: Noncompliance with earmarking requirements for Youth Program funds, specifically the 20% for work experiences and 75% for Out-of-School youth services.
  • Recommended Follow-Up: Implement quarterly monitoring of earmark requirements involving finance, planning, and youth program staff to ensure compliance and address issues promptly.

Finding Text

FINDING REFERENCE NUMBER 2022-001 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 2021-0000013 COMPLIANCE REQUIREMENT MATCHING, LEVEL OF EFFORT, EARMARKING TYPE OF FINDING NONCOMPLIANCE AND SIGNIFICANT DEFICIENCY CRITERIA WOIA 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). STATEMENT OF CONDITION During our audits test of the earmarking compliance requirement for the Youth Program funds of the program year 2020-2021, we noted that the Local Area only expended 2% 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, 2022. Also, the Local Area only expended 22% of the Youth Program funds allocated for program year 2020-2021 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 per our evaluation. (The sampling was a statistically valid sample.) STATEMENT OF CAUSE The Local Area fail 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 Repeat Finding ? Prior year Finding Number 2021-001. 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 on 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 The Corrective Action Plan in a continuous basis will be as follow: 1. The youth committee attached to the Northwest Local Board will comprise a representative from finance, budget and planning staff (youth program and executive) who will measure the achievement of the 20% benchmark on a quarterly basis. 2. This committee will take appropriate actions in order to verify the correctness of the expenditures according to the 20% expense requirement mentioned above. 3. This committee will provide to the Executive Director, recommendations to the operational areas in order to comply with the goal of expenditures required under sections 20 CFR 681.590, 681.460 (a)(3) and 681.600 of WIOA. 4. A report will be issue to the operational levels in accordance with the recommendations adopted by the Executive Director. 5. The public policy for the implementation of the work experience element of the youth program gave the opportunity to increase 2% of youth services. 6. The Northwest Local Area has established strategies for the dissemination of services for the youth program. This is done through the integration of social networks (Instagram and Facebook), radio, signs, press, television and official internet page. 7. The youth are, together with the promotion unit, established an itinerary of visits to the municipalities that comprise our area in order to carry out campaigns (Work Fairs) to guide our services and recruitment. 8. We will continue to join efforts through mass campaigns with an effective strategic plan to outreach the youth program. IMPLEMENTATION DATE Immediately RESPONSIBLE PERSONS Executive Director, Area Executive, MIS Director and Finance Director

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 37142 2022-001
    Significant Deficiency Repeat
  • 37143 2022-001
    Significant Deficiency Repeat
  • 613583 2022-001
    Significant Deficiency Repeat
  • 613584 2022-001
    Significant Deficiency Repeat
  • 613585 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
17.278 Wia Dislocated Worker Formula Grants $1.78M
17.258 Wia Adult Program $1.17M
17.259 Wia Youth Activities $830,300