Finding Text
Findings 2022-002: 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 (a)(4)(A), WIOA, 128 Stat. 1506 when utilizing the Youth Activities program funds. Accordingly, a minimum of 75 percent of the Youth Activities 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. Condition: The cumulative effect of the prior years? waivers that allowed the Organization to spend up to 50% of the youth activities funds for In-School-Youth activities hindered the Organization from fulfilling the 75% Youth Activities fund expenditures requirement. Context: Out of the funds allocated for the WIOA Youth Activities, only 70 percent of the total Youth Activities fund was used to provide service to out-of-school youth. Identification of Repeat Finding: Not applicable Questioned Cost: None Cause: The Kansas Department of Commerce/Workforce Services Division received a waiver from U.S. DOL/ETA during program years 2018 and 2019 that allowed all local workforce boards in the state to spend up to 50% of their WIOA Youth funds on In-School Youth (ISY). All local workforce boards, including Local Workforce investment Area III, Inc., were strongly encouraged to utilize the waiver and to actively recruit and enroll more ISY during the waiver period. Local Workforce Investment Area III, Inc. complied with that request and increased enrollments of ISY during this time. ISY enrollments made during the waiver period, however, continued to impact the total expenditure percentage split between ISY and Out-of-School Youth (OSY) in the fiscal year ended June 30, 2022 (program year 2021). The service and follow-up periods for many of the ?extra? ISY enrolled under the waiver naturally continued long past the closure of the waiver period, and any expenditures on behalf of those ISY (case management time, supportive services and training dollars) must accordingly continue to be allocated to ISY. As a result, the effect of the waiver was not experienced only during the waiver enrollment time frame, but also continues to result in higher ISY expenditures until those ISY finally roll off. In addition, Local Workforce Investment Area III continued enrolling Youth based on the expectation and understanding that the ISY expenditure waiver would be extended yet again for program year 2020. However, in August 2020, they were notified that the waiver had not been extended. This late notification also delayed an appropriate adjustment to their program enrollment practices to get back to the 75/25 requirements. Effect: Funds that was supposed to serve Out-of-School-Youth are used for the activities of In-School-Youth participants. 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.