Finding 45293 (2022-001)

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Requirement
G
Questioned Costs
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Year
2022
Accepted
2023-03-15

AI Summary

  • Core Issue: The Organization did not meet the 20% earmarking requirement for work experiences in the WIOA Youth Activities program, utilizing only 11.21% of funds.
  • Impacted Requirements: Compliance with the WIOA Act section 129 (c)(4) is essential for proper fund allocation towards youth work experiences.
  • Recommended Follow-Up: The Organization should either comply with the earmarking requirement or request a waiver from the federal funding agency.

Finding Text

Findings 2022-001: WIOA Youth Activities (CFDA # 17.259) Agency: Department of Labor Compliance: Earmarking Finding Type: Compliance Criteria: The Organization is required to comply with the WIOA Act section 129 (c)(4) when utilizing the Youth Activities program funds. Accordingly, not less than 20 percent of Youth Activities funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences to in-school and out-of-school youth. Condition: The Organization has not fulfilled the earmarking percentage requirement for work experience for youth activities. Context: Out of the funds allocated for the WIOA Youth Activities, only 11.21% was used to provide in-school youth and out-of-school youth with paid and unpaid work experiences. Identification of Repeat Finding: Yes, see Finding 2020-001. Questioned Cost: None Cause: The continued impact by the worldwide COVID-19 pandemic health crisis has caused on-going and significant reduction in youth enrollments thus resulting in a significant reduction of the number of youth work experience opportunities. In addition, the impact of the pandemic created significant staff shortages and prolonged vacancies which resulted in the inability to recruit youth enrollments and identify work experience opportunities overall. Finally, the unsubsidized labor market has created extreme competition in the ability to entice youth involvement in the WIOA Youth work experience program. Effect: Fund allocated for paid and unpaid work experience for Youth Activities was not fully utilized. Recommendation: We recommend that the Organization comply with the requirements or seek a waiver from the federal funding agency. View of Responsible Official: Management agrees with the finding. See the management?s views and corrective action plan.

Corrective Action Plan

Local Workforce Investment Area III, Inc Corrective Action Plan For the Year Ended June 30, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current and prior year auditor?s reports. The Corrective Action Plan for Current Year Findings present the Local Workforce Investment Area III Inc?s corrective action plan for the Federal Award Finding described in the accompanying Schedule of Prior Audit Findings for the period ended June 30, 2022 and the prior year finding listed in the summary of prior year findings. 2022-001 and 2020-001: Program: WIOA Youth Activities (CFDA # 17.259) Compliance: Earmarking Finding Type: Compliance Agency: US Department of Labor Internal Control Impact: None Finding: Per WIOA Act section 129 (c)(4), not less than 20 percent of Youth Activities funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences to in-school and out-of-school youth. The Local Area has not fulfilled the percentage requirement. Out of the funds allocated for the WIOA Youth Activities, only 11.21% and 17.63% were used to provide in-school youth and out-of-school youth with paid and unpaid work experiences in 2022 and 2020, respectively. Status: Corrective Action In-Progress Corrective Action Plan: Local Workforce Investment Area III, Inc. closely tracked its youth work experience percentage during program year 2021, and was aware that its percentage was too low due to a very low number of youth enrollments for the year. Knowing that action needed to be taken to increase youth enrollments, which would naturally increase work experience expenditures, it began taking steps to understand and rectify the problem in spring 2022. Local Workforce Investment Area III, Inc.?s WIOA Youth Provider, Dynamic Workforce Solutions, hired Thomas P. Miller and Associates (TPMA) to provide consultative services to assist in the development of new outreach and recruitment strategies and of new ideas to improve retention of youth during work experiences. In addition, Local Workforce Investment Area III, Inc. convened its Youth Committee on two distinct occasions specifically to discuss these issues and to provide guidance to staff, including a review of and feedback on the TPMA draft report. As a result of TPMA?s research and these consultations, Local Workforce Investment Area III, Inc. made the following Youth Program modifications to improve its overall enrollment numbers and increase its work experience expenditures: ? A personnel change was made to improve work experience/work-based learning worksite outreach, recruitment, and participant placements. ? To further expand the potential pool of worksites, strategic efforts were undertaken to foster closer coordination between the Youth Team and the Local Area?s Business Services Team. ? Full Youth Team staffing was achieved after a prolonged period of vacancies and staff shortages emerging from the pandemic. ? Staff training and outreach and recruitment strategies and tactics were re-orientated to focus squarely work experience and work-based learning as the service option of first and priority resort. ? All youth outreach flyers, communication and collateral materials were revamped/refreshed to present an appropriate value proposition to prospective youth participants with a pronounced emphasis on earning and learning through work-based learning. ? Program service plans were strategically arranged to increase the volume of individuals who received technical, classroom-based certification training coupled with a complementary work-based learning experience. ? Website content was refreshed to reemphasize and promote work-based learning as a critical employment solution and a Youth service of first-resort. ? Work experience policies and pay rates were reviewed and adjusted upward to the degree allowed for a closely alignment with trends in the unsubsidized labor market. Local Workforce Investment Area III, Inc. is confident in its corrective actions taken thus far, as it experienced excellent increases in enrollment numbers starting in early summer 2022 which have continued through PY22. As a result of these efforts, the current work experience expenditure percentage is already at 19.60% as of January 2023, with 5 more months yet remaining in the program year. Person(s) Responsible for Implementation: Keely Schneider Implementation Date: June 30, 2023.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
17.258 Wia Adult Program $1.14M
17.259 Wia Youth Activities $346,901
17.274 Youthbuild $223,366
11.307 Economic Adjustment Assistance $111,624
17.720 Disability Employment Policy Development $107,643
17.278 Wia Dislocated Worker Formula Grants $66,887
17.270 Reintegration of Ex-Offenders $59,138
94.006 Americorps $36,056
16.726 Juvenile Mentoring Program $19,679
93.093 Affordable Care Act (aca) Health Profession Opportunity Grants $6,689