Office of Inspector General—Office of Audit 

 

 

EMPLOYMENT AND 

TRAINING 

ADMINISTRATION 

RECOVERY ACT: WORKFORCE INVESTMENT 

ACT YOUTH PROGRAM 

This audit was performed by Ollie Green & Company, CPA’s, under contract to 

the Office of Inspector General, and by acceptance, it becomes a report of the 

Office of Inspector General. 

 _____________________________ 

Assistant Inspector General for Audit 

Date Issued: March 31, 2011 

Report Number: 18-11-006-03-390 
 

 

 

 

U.S. Department of Labor 

Office of Inspector General 

Office of Audit 

BRIEFLY... 

Highlights of Report Number: 18-11-006-03-390, to the 

Assistant Secretary for Employment and Training. 

WHY READ THE REPORT 

Congress enacted the American Recovery and 

Reinvestment Act of 2009 (Recovery Act), to promote 

economic recovery and assist those impacted by the 

recession. Title VIII of the Recovery Act provided the 

Department of Labor (DOL) with an additional $1.2 

billion in Workforce Investment Act (WIA) formula funds 

for youth employment and training activities. These 

funds are administered by the Employment and 

Training Administration (ETA). The Act allowed the 

Department to retain 1 percent ($12 million) of these 

funds for program administration and oversight. 

WHY OIG CONDUCTED THE AUDIT 

The Office of Inspector General (OIG) conducted an 

audit to determine how Local Areas are using the 

additional WIA Youth Program funds provided by the 

Recovery Act, and to determine the impact of extending 

the age limit from 21 to 24 year old youth – both in 

terms of participants served in that age range, the 

services provided to the extended population, and the 

outcomes achieved. Specifically, our audit objectives 

were to answer the following questions: 

(1) How did Local Areas spend or how were they 

planning to spend their allocation of WIA Youth Formula 

Funds? 

(2) Who were the participants in the WIA Youth 

Program? 

(3) What services were participants in the WIA Youth 

Program receiving? 

(4) What were the outcomes for participants enrolled in 

the WIA Youth Program? 

(5) To what extent were employers using the Work 

Opportunity Tax Credit to hire disconnected youth (ages 

16 to 24) as provided by the Recovery Act? 

READ THE FULL REPORT 

To view the report, including the scope, methodology, 

and full agency response, go to: 

http://www.oig.dol.gov/public/reports/oa/2011/18-11-

006-03-390.pdf 

March 2011 

RECOVERY ACT: WORKFORCE INVESTMENT ACT 

Youth Program 

WHAT OIG FOUND 

The OIG found that Local Areas had spent $1.044 

billion of their Recovery Act WIA Youth funding by 

September 30, 2010, and that 80 percent of those funds 

were spent on summer employment opportunities and 

paid and unpaid work experiences consistent with 

ETA’s Recovery Act program goals. We also noted that 

$5.8 million was spent on green industry activities (i.e., 

solar, recycling, etc.). 

We found that 49 percent of WIA Youth Program 

participants were 14-17 years old and that a majority 

were minorities. Participants received services in all 10 

Section 129 program elements, to include summer 

employment opportunities, tutoring, and adult 

mentoring. These services contributed to the attainment 

of work readiness skills for 76 percent of participants 

and to the attainment of part-time or full-time 

employment for 9 percent. 

Local Areas did not track the use of the Work 

Opportunity Tax Credit by employers. 

WHAT OIG RECOMMENDED 

There were no findings and recommendations as a 

result of this audit. ETA agrees with the audit results 

contained in this report. 
 

 

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Recovery Act: WIA Youth Program 

Report No.18-11-006-03-390 
 

 

 


	


	


	


	


	


	


	


	


	


	


	


	


	


	


	


	


	

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Table of Contents 

Independent Auditor’s Report...................................................................................... 1
	

Objective 1 — How did Local Areas spend or are planning to spend their 

allocation of WIA Youth Formula Funds? .......................................... 3
	

Local Areas spent 80 percent of their Recovery Act WIA youth allocation 

on summer employment opportunities and part-time and full-time work 

experiences. ......................................................................................................... 3
	

Objective 2 — Who are the participants in the WIA Youth Program? ...................... 5
	

Participant ages 14-17 years old represented 49 percent of the Recovery 

Act WIA Youth Program enrollment...................................................................... 5
	

Objective 3 — What services are participants in the WIA Youth Program 

receiving? ............................................................................................. 8
	

Participants enrolled in the Recovery Act WIA Youth Program received 

services in all 10 Section 129 program elements. ................................................ 8
	

Objective 4 — What were the outcomes for participants enrolled in the WIA Youth 

Program? .............................................................................................. 9
	

Attainment of work readiness skills represented 76 percent of the 

outcomes for participants enrolled in the Recovery Act WIA Youth 

Program................................................................................................................ 9
	

Objective 5 — To what extent were employers using the Work Opportunity Tax 

Credit to hire disconnected youth (ages 16-24) as provided by the 

Recovery Act? .................................................................................... 10
	

Local Areas did not track employer’s use of the Work Opportunity Tax 

Credit.................................................................................................................. 10
	

Exhibit 

Exhibit 1 Recovery Act LWIB/INA Sample.......................................................... 15
	

Appendices 

Appendix A Background ..................................................................................... 21
	

Appendix B Objectives, Scope, Methodology, and Criteria ................................ 23
	

Appendix C Acronyms and Abbreviations .......................................................... 27
	

Appendix D ETA Response to Draft Report ....................................................... 29
	

Appendix E Acknowledgements ......................................................................... 31
	

Recovery Act: WIA Youth Program 

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Recovery Act: WIA Youth Program 

Report No.18-11-006-03-390 
 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Independent Auditor’s Report 

Ms. Jane Oates 

Assistant Secretary for Employment and Training 

Employment and Training Administration 

U.S. Department of Labor 

200 Constitution Avenue, NW 

Washington, D.C. 20210 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) was passed to 

preserve and create jobs, promote economic recovery, and assist those most impacted 

by the recession. Title VIII of the Recovery Act provided the Department of Labor with 

an additional $1.2 billion in Workforce Investment Act (WIA) formula funds for youth 

employment and training activities. The Recovery Act also extended the youth eligibility 

age from 21 to 24. The Recovery Act allows states and outlying areas, and Indian and 

Native American grantees to spend additional WIA Youth Program funds on activities 

related to any of the 10 program elements described in Section 129 of WIA. Because 

the Recovery Act allows the Department to retain one percent (1 percent) of the funds 

for program administration and oversight, the actual allotment to the States and outlying 

areas and Indian and Native American grantees was $1.188 billion. Grantees have until 

June 30, 2011, to spend these additional funds. 

Our audit objectives were to determine (1) how Local Areas spent or were planning to 

spend their allocation of Recovery Act WIA Youth Formula Funds; (2) who were the 

participants in the Recovery Act WIA Youth Program; (3) what services were 

participants in the Recovery Act WIA Youth Program receiving; (4) what were the 

outcomes for participants enrolled in the Recovery Act WIA Youth Program; and (5) to 

what extent were employers using the Work Opportunity Tax Credit to hire disconnected 

youth (ages 16 to 24) as provided by the Recovery Act. 

The audit included a review of documents and data available from ETA’s office. It 

included structured interviews and data collection instruments administered to heads of 

State Youth Program offices or their designees in a stratified universe of 830. The 

interviews were conducted during November 2010 through February 2011, and included 

available data through September 30, 2010. 

Recovery Act: WIA Youth Program 

1 Report No.18-11-006-03-390 
 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

RESULTS IN BRIEF 

We estimated, based on the results of our sample, that Local Workforce Investment 

Boards and Indian and Native American grantees (LWIB/INA) spent 80 percent of their 

allocation of Recovery Act funds on summer employment opportunities and paid and 

unpaid work experiences. These two categories are allowable program 

activities/elements under WIA Section 129. LWIB/INAs spent $415.5 million (40 

percent) of their Recovery Act WIA Youth Program funds on summer employment 

opportunities. Another $416.1 million (40 percent) was spent on paid and unpaid work 

experience as of September 30, 2010. 

Based on our sampling results, we estimated $24.8 million (36 percent) of LWIB/INAs 

“unused” Recovery Act funds would be spent on “other,” while $20.8 million (30 percent) 

of these unused funds would be spent on paid and unpaid work experiences by the 

June 30, 2011, cutoff date. We estimated they would spend $12.4 million (18 percent) 

of their unused Recovery Act funds for follow-up services. We also estimated that 

LWIB/INAs spent $5,876,646 of their Recovery Act WIA Youth funds on green industry 

activities. 

Our audit found that most participants enrolled in the Recovery Act WIA Youth Program 

were between the ages of 14 and 17 years old. We also found that program 

administrators enrolled eligible participants from many cultures. African Americans 

represented 47 percent of the participants while Hispanics represented another 16 

percent. Caucasians represented 27 percent of the participants enrolled. We found 

that 10 percent of the participants enrolled in the Recovery Act WIA Youth Program fell 

within the Recovery Act expanded age range (22-24). We also noted that veterans 

represented less than one percent (1 percent) of the total participant enrollment. 

We found that LWIB/INAs enrolled more than 460,000 eligible participants in the 

Recovery Act WIA Youth Program and provided eligible youth with activities and 

services related to all 10 of the WIA Section 129 program elements. Many of the 

participants received services and activities in more than one program element 

category. 

Our audit found that the outcome for 349,502 (76 percent) of the participants enrolled in 

the Recovery Act WIA Youth Program was the attainment of work readiness skills. 

Part-time and full-time employment accounted for 40,635 (9 percent) of the total 

outcomes of the Recovery Act Youth Program. We also found that 7,915 (1 percent) 

received secondary school diplomas, while 8,769 (2 percent) received post secondary 

education. 

Finally our audit found that LWIB/INAs were not required to track the Work Opportunity 

Tax credit (WOTC) used by employers to hire “disconnected youth,” ages 16 to 24, as 

provided by the Recovery Act. Although 14 of the respondents surveyed indicated that 

they had implemented systems designed to track the WOTC used by employers; fortyeight others told us that they did not have systems in place designed to track the use of 

Recovery Act: WIA Youth Program 

2 Report No.18-11-006-03-390 
 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

the credit and another 21 told us that they could not determine whether they had 

systems in place to track the use of the credit. We found that States are required to 

submit quarterly reports that provide information on applications received, certified 

and/or denied. These reports include information on the two new target groups, 

disconnected youth and unemployed veterans. 

ETA agrees with the audit results and believes the positive results demonstrate that 

ETA effectively implemented the Recovery Act Youth activities funding provided by 

Congress. ETA’s comments are included in their entirety in Appendix D. 

There were no findings and recommendations as a result of this audit. The OIG has 

made technical changes in the report based on comments ETA provided in response to 

the draft report. We believe ETA complied with Recovery Act WIA activities funding 

requirements. 

RESULTS 

Objective 1 — How did Local Areas spend or how were they planning to spend 

their allocation of WIA Youth Formula Funds? 

Local Areas spent 80 percent of their Recovery Act WIA youth allocation on 

summer employment opportunities and part-time and full-time work experiences. 

As indicated in Table 1 below, LWIB/INAs spent an estimated $1.044 billion of their 

Recovery Act formula funding by September 30, 2010; our audit found, based on 

sampling results, that $68.5 million had not yet been spent. The Recovery Act requires 

that all WIA formula funds are expended by June 30, 2011. Most LWIB/INAs indicated 

that they planned to spend their unused funds by the June 30, 2011 deadline. Table 1 

also illustrates that LWIB/INAs spent most of their Recovery Act WIA Youth Program 

funds on summer employment opportunities (40 percent) and paid and unpaid work 

experiences (40 percent). LWIB/INAs spent (80 percent) of their allocation of Recovery 

Act funds in these two categories. 

Recovery Act: WIA Youth Program 

3 Report No.18-11-006-03-390 
 

WIA Program Elements/Activities Amount Planned By 6/30/11 Percent 

Tutoring, study skills training $206,641 1 

Alternative secondary school offerings 572,057 1 

Summer employment opportunities 529,538 1 

Paid and unpaid work experiences 20,873,062 30 

Occupational skills training 5,179,652 8 

Leadership development opportunities 1,208,233 1 

Supportive services 2,004,351 2 

Adult mentoring 168,240 1 

Follow-up services 12,478,341 18 

Comprehensive guidance and counseling 456,790 1 

Other2 24,827,015 36 

Total $68,503,920 100 

 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Table 1: Extrapolated Spending by Section 129 Allowable Program Elements 

and Activities 

WIA Program Elements/Activities Amount Spent By 9/30/10 Percent 

Tutoring, study skills training $3,491,972 1 

Alternative secondary school offerings 915,649 1 

Summer employment opportunities 415,565,223 40 

Paid and unpaid work experiences 416,165,462 40 

Occupational skills training 13,041,671 1 

Leadership development opportunities 15,771,706 1 

Supportive services 34,539,817 3 

Adult mentoring 4,797,232 1 

Follow-up services 1,753,721 1 

Comprehensive guidance and counseling 26,286,954 2 

Other1 112,456,546 9 

Total $1,044,785,953 100 

As indicated in Table 2 below, LWIB/INAs also told us in surveys and data collection 

instruments that of their $68.5 million unused Recovery Act funding at September 30, 

2010, $24.8 million would be spent on “other,” $20.8 million on paid and unpaid work 

experiences, and $12.4 million for follow-up services. LWIB/INAs also indicated that 

$5.8 million of their Recovery Act WIA Youth funds were spent on green industry 

activities (i.e. solar, recycling, etc, etc). 

Table 2 : Projected Spending For Unused Recovery Act Funds 

1 Includes unallocated indirect program and other administrative costs. 2 Include unallocated indirect program and other administrative costs. 

Recovery Act: WIA Youth Program 

4 Report No.18-11-006-03-390 
 

Ages Participant Count Percent 

14-15 80,013 17 

16-17 145,426 31 

18-19 131,179 28 

20-21 61,816 14 

22-24 44,609 10 

Total 463,043 100 

 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Objective 2 — Who were the participants in the WIA Youth Program? 

Participant ages 14-17 years old represented 48 percent of the Recovery Act 

WIA Youth Program enrollment. 

The objective of this part of our audit was to determine who were the participants 

enrolled in the Recovery Act WIA Youth Program. To conduct our work, we requested 

LWIB/INAs to provide data on the characteristics of the participants enrolled from 

Recovery Act inception (February 17, 2009) through September 30, 2010. Tables 3 

through 9 below summarize the characteristics of the participants enrolled from 

Recovery Act inception through September 30, 2010, by participant count and seven 

different categories.3 

Table 3 below shows that 225,439 (48 percent) of the participants enrolled were within 

the age range of 14 to 17. Another 131,179 (28 percent) fell within the 18 to 19 age 

range. Title VIII (Division A) of the Recovery Act temporarily extended the age limit 

from 21 to 24; this expanded age range accounted for only 44,609 (10 percent). 

Table 3: Projected Participant Ages 

Table 4 below shows that 353,704 (96 percent) of the participants who enrolled in the 

Recovery Act WIA Youth Program were unemployed at enrollment. Fifteen of the 

respondents surveyed did not track this information or did not respond to this question 

in our survey/DCI. 

Table 4: Projected Employment Status at Enrollment 

Participant Employment Status Participant Count Percent 

Employed 14,858 4 

Unemployed 353,704 96 

Total 368,562 100 

3 Total participant counts in Tables 3 through 9 may not align because not all respondents answered all DCI 

questions. 

Recovery Act: WIA Youth Program 

5 Report No.18-11-006-03-390 
 

Participant Gender Participant Count Percent 

Male 229,356 50 

Female 229,843 50
	
	

Total 459,199 100 

Race Participant Count Percent 

African American 213,895 47 

American Indian or Alaskan 15,327 3 

Asian 6,854 1 

Caucasian 126,177 27 

Hawaiian or Pacific Islander 8,286 2 

Hispanic 76,082 16 

More Than One Race 8,006 2 

Other 7,177 2 

Total 461,804 100 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Table 5 below shows that a slight majority 229,843 (50 percent) of the participants 

enrolled in the Recovery Act WIA Youth Program were female. Our audit found that 

there was a virtual even gender split for participant enrolled in the Recovery Act WIA 

Youth Program as of September 30, 2010. 

Table 5: Projected Gender 

Table 6 below shows that most participants enrolled in the Recovery Act WIA Youth 

program were minority youth. We found that 213,895 (47 percent) of the participants 

enrolled in the Recovery Act WIA Youth Program were of African American heritage. 

Another 76,082 (16 percent) participants were of Hispanic heritage. However, Table 6 

also illustrates that program administrators recruited and enrolled a diverse group of 

participants from many cultures. Caucasians represented 27 percent of the participants 

enrolled. 

Table 6: Projected Race and Ethnicity 

Table 7 below indicates that 602 (58 percent) of the veterans who enrolled in the 

Recovery Act WIA Youth Program fell within the Recovery Act expanded age range of 

22 to 24. Veterans were a very small percentage of the Recovery Act WIA Youth 

Program; less than 1 percent of the total participant enrollment. 

Recovery Act: WIA Youth Program 

6 Report No.18-11-006-03-390 
 

Veteran Ages Participant Count Percent 

19-21 444 42 

22-24 602 58
	
	

Total 1,046 100 

Barriers to Employment Participant Count Percent 

Homeless of Runaway 9,527 4
	
	

Offender 25,428 9
	
	

Pregnant of parenting youth 51,545 19 

Basic literacy skills deficient 116,493 42 

Other 71,264 26 

Total 274,257 100 

Table 8: Projected Barriers to Employment 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Table 7: Projected Veterans 

Table 8 below shows that 116,493 (42 percent) participants were basic literacy skill 

deficient. Another 51,545 (19 percent) participants were pregnant or parenting youth. 

Twelve of the respondents surveyed did not track this information or did not respond to 

this question in our survey/DCI. 

Table 9 below shows that 239,427 (66 percent) participants had not completed high 

school. This group included 41,226 (11 percent) participants who had completed 

middle school as their highest grade. Table 9 also shows that 121,854 (34 percent) had 

completed high school, high school equivalency, post -secondary and/or college. This 

group also included 1,599 (1 percent) college graduates. Eighteen of the respondents 

surveyed did not track this information or did not respond to this question in our 

survey/DCI. 

Table 9: Projected Education 

Highest Grade Completed Participant Count Percent 

Middle School 41,226 11 

Some High School 198,201 55 

High School Graduate 82,868 23 

High School Equivalency 10,074 3 

Some Post-Secondary 27,313 7 

College Graduate - 4 Year 1,599 1 

Total 361,281 100 

Recovery Act: WIA Youth Program 

7 Report No.18-11-006-03-390 
 

WIA Program Elements Participant Count Percent 

Tutoring, study skills training 11,612 1 

Alternative secondary school offerings 2,074 1 

Summer employment opportunities 254,542 26 

Paid and unpaid work experiences 244,187 25 

Occupational skills training 11,980 1 

Leadership development opportunities 73,464 7 

Supportive services 139,730 14 

Adult mentoring 21,087 2 

Follow-up services 24,481 2 

Comprehensive guidance and counseling 86,678 9 

Other4 123,880 12 

Total 993,715 100 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Objective 3 — What services were participants in the WIA Youth Program 

receiving? 

Participants enrolled in the Recovery Act WIA Youth Program received services 

in all 10 Section 129 program elements. 

The objective of this part of our audit was to determine what services were received by 

participants enrolled in the Recovery Act WIA Youth Program from Recovery Act 

inception to September 30, 2010. We requested respondents to provide information on 

services provided to participants enrolled in their WIA Youth Programs. We found that 

LWIB/INAs provided services to participants in all 10 of the Section 129 program 

elements. 

Table 10 below shows that 993,715 participants received services through the Recovery 

Act WIA Youth Program. This number is inflated for participants who received services 

in more than one program element category. 

Table 10 : Projected Services Received by Participant Count 

Table 11 below illustrates services received by dollar amount. LWIB/INAs spent an 

estimated $1.044 billion of their Recovery Act WIA Youth Program funds by September 

30, 2010. As indicated, 80 percent of the services received by participants were 

concentrated in the summer employment opportunities and paid and unpaid work 

experiences categories. These activities are consistent with the LWIB/INAs spending 

assessment discussed in objective number one. 

4 Some respondents indicated that they could not determine which category was most appropriate 

Recovery Act: WIA Youth Program 

8 Report No.18-11-006-03-390 
 

WIA Program Elements/Activities Amount Spent By 9/30/10 Percent 

Tutoring, study skills training $3,491,972 1 

Alternative secondary school offerings 915,649 1 

Summer employment opportunities 415,565,223 40 

Paid and unpaid work experiences 416,165,462 40 

Occupational skills training 13,041,671 1 

Leadership development opportunities 15,771,706 1 

Supportive services 34,539,817 3 

Adult mentoring 4,797,232 1 

Follow-up services 1,753,721 1 

Comprehensive guidance and counseling 26,286,954 2 

Other5 112,456,546 9 

Total $1,044,785,953 100 

Objective 4 — What were the outcomes for participants enrolled in the WIA Youth 

Program? 

Attainment of work readiness skills represented 76 percent of the outcomes for 

participants enrolled in the Recovery Act WIA Youth Program. 

Our audit found that LWIB/INAs, had implemented systems designed to track the 

outcomes of participants who enrolled in their Recovery Act WIA Youth Programs. 

Tracking youth participation is required to manage the process of keeping participants 

on track for completion of short-term skill attainment goals and preparation to move into 

long-term employment, education, or training. We requested LWIB/INAs to provide 

information on the outcomes of participants enrolled in the Recovery Act WIA Youth 

Program from Recovery inception through September 30, 2010. TEGL 14-08 specifies 

that “Any youth served with only Recovery Act funds that participates in summer 

employment only, will only be included in the Youth Recovery Act report and the work 

readiness indicator will be the only measure that applies to such youth.” Recovery Act 

H.R.1-58 Title VIII (2) provides “That the work readiness performance indicator 

described in section 136(b) (2) A (ii) (I) of the WIA shall be the only measure of 

performance used to assess the effectiveness of summer employment for youth 

provided with such funds.” 

Table 12 illustrates that the outcome for 349,502 (76 percent) of the participants 

enrolled in the Recovery Act WIA Youth Program was the attainment of work readiness 

 

5 Include unallocated indirect program and other administrative costs. 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Table 11: Projected Services Received by Participants by Dollar Amount 

Recovery Act: WIA Youth Program 

9 Report No.18-11-006-03-390 
 

Table 12 : Projected Participant Outcomes 

 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

skills. As illustrated in Table 11 above, 40 percent of Recovery Act WIA Youth Program 

funding was spent on summer youth employment opportunities. Because Recovery Act 

H.R.1-58 Title VIII (2) provides “That the work readiness performance indicator 

described in section 136(b) (2) A (ii) (I) of the WIA shall be the only measure of 

performance used to assess the effectiveness of summer employment for youth 

provided with such funds,” the level of attainment of work readiness skills outcome 

reported in Table 12 below is consistent with the level of summer youth employment 

funding level reported in Table 11. Part-time and full-time employment accounted for 

40,635 (9 percent) of the total outcomes of the Recovery Act Youth Program. Another 

7,915 (1 percent) participants received secondary school diplomas, while 8,769 (2 

percent) received post-secondary education. 

Outcomes Participant Count Percent 

Post-secondary Education 8,769 2 

Advanced Training 3,832 1 

Apprenticeships 66 1 

Military Service 113 1 

Full-Time Employment 14,549 3 

Part-Time Employment 26,086 6 

Secondary School Diploma 7,915 1 

High School Equivalency Diploma (GED) 1,709 1 

Basic Skills 13,897 3 

Occupational Skills 12,155 2 

Work Readiness Skills 349,502 76 

Other6 21,743 5 

Total 460,336 100 

Objective 5 — To what extent were employers using the Work Opportunity Tax 

Credit to hire disconnected youth (ages 16-24) as provided by the 

Recovery Act? 

Local Areas did not track employer’s use of the Work Opportunity Tax Credit. 

The objective of this segment of our audit was to determine to what extent employers 

were using the WOTC to hire disconnected youth (ages 16-24) as provided by the 

Recovery Act. The Work Opportunity Tax Credit (WOTC) Program was created in 1996 

by the Small Business Job Protection Act. The program provides a tax credit to 

private-sector businesses to hire individuals from 12 target groups who have 

consistently faced significant barriers to employment, including the two new target 

groups (Unemployed Veterans and Disconnected Youth) authorized by the Recovery 

Act. Our approach included surveying LWIB/INAs and using DCIs to collect information 

6 Some respondents indicated they were not able to determine the outcome. 

Recovery Act: WIA Youth Program 

10 Report No.18-11-006-03-390 
 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

to determine whether systems were implemented to track the WOTC used by 

employers who had hired disconnected youth. 

Our audit found that LWIB/INAs were not required to track the use of the WOTC by 

employers. Although 14 of the respondents surveyed indicated they or their State had 

implemented systems designed to track the WOTC used by employers, 48 others told us 

they did not, and 21 told us they could not determine whether or not they had systems in 

place to track the use of the credit. ETA indicated that LWIB/INAs were not required to 

track this information. 

Based on information provided to us by LWIB/INAs in their surveys/DCIs, we could not 

determine the extent that employers used the WOTC to hire disconnected youth as 

provided by the Recovery Act. However, ETA provided information based on data 

collected by States in their quarterly reports to ETA indicating that employers had sought 

the WOTC for 135,013 disconnected youth through the quarter ended September 30, 

2010. We did not audit this information. 

Consistent with the Recovery Act, States were required to submit quarterly reports, 

which provide information on applications received, certified and/or denied. These 

reports include information on the two new target groups, disconnected youth and 

unemployed veterans. An individual qualifies as a disconnected youth if they are 

between the ages of 16 and 25 and have not been regularly employed or attended 

school in the past 6 months, or they are not readily employable due to lack of basic 

skills. 

Our audit also found that State Workforce Agencies (SWA) administer the WOTC and 

assist with the timely processing of applications. The operational management of the 

WOTC certification process includes 1) determining whether the certification requests 

were received in a timely manner, 2) verifying target group eligibility with different state 

service providers, and 3) issuing to employers the state’s final determination (i.e., a 

certification or denial). ETA Handbook 408 was revised to reflect the 2 new target 

groups introduced by the Recovery Act and its statutory requirements. TEGL 3-09 

issued on September 1, 2009, provided information and guidance to SWAs on the 

effective and timely implementation of eligibility certification for the two new targeted 

groups. 

There were no findings and recommendations as a result of this audit. 

We appreciate the cooperation and courtesies that ETA, State and LWIB/INA personnel 

extended to Ollie Green & Company, CPA’s during this audit. 

Ollie Green, MBA, CPA 

Managing Partner 

Recovery Act: WIA Youth Program 

11 Report No.18-11-006-03-390 
 

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for U. S. Department of Labor – Office of Inspector General 

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Recovery Act: WIA Youth Program 

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for U. S. Department of Labor – Office of Inspector General 

Exhibit 

Recovery Act: WIA Youth Program 

13 Report No.18-11-006-03-390 
 

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for U. S. Department of Labor – Office of Inspector General 

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Recovery Act: WIA Youth Program 

14 Report No.18-11-006-03-390 
 

 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Exhibit 1 

Recovery Act LWIB/INA Sample 

Local Workforce Investment Boards Allotment 

1 NY New York City $32,246,944 

2 CA Los Angeles City 20,318,324 

3 IL LWIA 9- City of Chicago 17,390,077 

4 CA Los Angeles County 14,920,052 

5 TX Gulf Coast 14,761,027 

6 OH Multiple Counties 13,507,380 

7 MI DWDD (Detroit Workforce Development Dept) 11,437,983 

8 CA San Diego County 10,499,924 

9 CA Riverside County 9,447,056 

10 OH Urban Youth Works/Recovery Conservation Corps 8,423,777 

11 CA Fresno City/County 7,836,652 

12 PA SE090 Philadelphia 7,399,628 

13 AL Local Area 2 (AL Workforce Investment Area) 7,374,798 

14 FL South Florida Workforce Board-Miami Dade Monroe 7,282,783 

15 CA San Bernardino County 7,141,256 

16 TX Dallas 6,842,698 

17 KY EKCEP (Eastern KY Concentrated Employment Program Inc) 6,549,836 

18 OH Cuyahoga County 6,367,690 

19 IL LWIA 7- Cook County 5,676,547 

20 TX Alamo 5,148,185 

21 TN Title 1 Youth LWIB #13 4,931,958 

22 MI Oakland 4,904,733 

23 CA San Jose/Silicon Valley 4,744,413 

24 MS Delta Local Workforce Investment Area 3,606,715 

25 NY Disconnected Youth Contract Program 3,581,359 

26 MD Baltimore City 3,558,951 

27 MI Capital 3,295,032 

28 GA Atlanta Regional 3,077,911 

29 NJ Newark 3,039,033 

30 SD ARRA Youth funds allotted to local area 2,884,250 

31 MA Area Hampden 2,562,282 

32 FL Tampa Bay Workforce Alliance Inc-Hillsborough 2,534,737 

33 GA DeKalb County 2,327,610 

34 KS Area 3 2,305,925 

35 TX Capital Area 2,213,498 

36 TN Title 1 Youth LWIB #5 2,197,182 

37 ND Youth Training Program 2,180,000 

38 WA S. Central 1,794,212 

39 LA LWIA 20 1,737,439 

40 PA NE075 Luzerne/Schuylkill Counties 1,625,837 

41 MO Southeast 1,556,471 

42 CA Santa Cruz County 1,535,571 

43 NY Onondaga County 1,304,591 

44 AR Northeast 1,297,451 

45 KS Area 4 1,244,014 

46 NC NC Div Juvenile Justice-Youth Detention Ctrs 951,630 

47 IA Region 16 (SDA 16) 935,128 

Recovery Act: WIA Youth Program 

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48 ME Area ll (Hancock, Penobscot, Piscataquis) 919,114 

49 MO Jefferson/Franklin Consortium 892,962 

50 OK South East 886,161 

51 PA NW145 West Central Job Partnership 884,732 

52 OR Workforce Investment Council of Clackamas County (WICCO) 848,393 

53 NJ Essex 810,357 

54 WI WDA #08 West Central 806,099 

55 AZ Tribal 787,132 

56 CO Tri-County 774,990 

57 GA Middle Georgia 773,713 

58 MO St. Charles County 748,761 

59 MD Lower Shore 718,293 

60 VI Local Youth Program 694,487 

61 NC Region C 666,464 

62 AR Western 638,111 

63 WI WDA #11 Southwest 601,346 

64 CA Cal GRIP Youth Awardees-City Impact 500,000 

65 NP WIA Youth ARRA 435,327 

66 IN Region 8 411,432 

67 NC Mountain Area 407,936 

68 MN Anoka County 363,949 

69 LA LWIA 50 354,592 

70 NH NH JAG 349,736 

71 NC Northeastern 308,758 

72 ID Region II 212,692 

73 FL Milestone Soc Srvs Inc Milestone Work-Aging Out Foster Care Proj 250,000 

74 MD Southern MD 110,344 

75 AZ Graham 80,811 

76 AZ Navajo Nation 3,956,397 

77 HI Alu Like, Inc. 2,411,092 

78 OK Cherokee Nation of Oklahoma 871,304 

79 OK Creek Nation of Oklahoma 458,763 

80 OK Choctaw Nation of Oklahoma 375,978 

81 AZ White Mountain Apache Tribe 343,210 

82 SD Rosebud Sioux Tribe 315,615 

83 AZ Tohono O'Odham Nation 288,020 

84 AZ San Carlos Apache Tribe 286,295 

85 OK United Urban Indian Council, Inc. 256,976 

86 CA California Indian Manpower Consortium, Inc. 195,233 

87 MN Red Lake Tribal Council 108,654 

88 MS Mississippi Band of Choctaw Indians 87,613 

89 MT Fort Belknap Indian Community 65,538 

90 CO Southern Ute Indian Tribe 13,798 

91 NY Seneca Nation of Indians 41,392 

92 NM Eight Northern Indian Pueblo Council 35,183 

93 WI Wisconsin Indian Consortium 34,149 

94 AK Kenaitze Indian Tribe 29,320 

95 MN Fond Du Lac R.B.C. 23,455 

96 TX Ysleta del Sur Pueblo 22,420 

97 AK Orutsararmuit Native Council 20,696 

98 NV Shoshone-Paiute Tribes 18,972 

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99 OR Confed. Tribes of the Umatilla Indian Res 18,972 

100 AK Aleutian/Pribilof Islands Association 15,522 

101 NM Pueblo of Isleta 15,177 

Total $315,046,986 

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Appendices 

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Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Appendix A 

Background 

The Recovery Act was signed into law by the President on February 17, 2009, to 

preserve and create jobs, promote economic recovery, and assist those most impacted 

by the recession. As of August 19, 2010, Congress had provided $70.8 billion7 in 

Recovery Act funds to DOL to, among other things, provide summer employment 

opportunities for youth and increase employment and training opportunities. The stated 

purposes of the Recovery Act were to: 

•	 Preserve and create jobs and promote economic recovery; 

•	 Assist those most impacted by the recession; 

•	 Provide investments needed to increase economic efficiency by spurring 

technological advances in science and health; 

•	 Invest in transportation, environmental protection, and other infrastructure 

that will provide long-term economic benefits; and stabilize state and local 

government budgets, in order to minimize and avoid reductions in essential 

services and counterproductive state and local tax increases. 

The Recovery Act required agencies to implement an unprecedented level of 

transparency and accountability to ensure the public can see where and how their tax 

dollars are being spent and recipients of these funds deliver programmatic results. 

The Workforce Investment Act of 1998 enacted a formula-funded youth program serving 

eligible low-income youth, ages 14-21, who face barriers to employment. Funds for 

youth services were allocated to States and Local Areas based on a formula 

distribution. Service strategies, developed by workforce providers, prepare youth for 

employment and/or post-secondary education through strong linkages between 

academic and occupational learning. Local communities provide youth activities and 

services in partnership with the WIA One-Stop Career Center System and under the 

direction of local Workforce Investment Boards. 

Section 129 of WIA described the purposes of the WIA Youth Program (Section a) and 

the allowable activities and services on which States and Local Areas can spend funds 

(Section c). Additionally, WIA required that at least 30 percent of the funds be spent on 

out-of-school youth. In fiscal year 2010, Congress appropriated more than $924 million 

for the WIA Youth Program. For Program Year 2008, ETA reported that the WIA Youth 

Program served 275,243 young people and achieved a 66 percent placement rate in 

employment or education—higher than the planned goal of 59 percent. 

The Division of Youth Services (within ETA’s Office of Workforce Investment) has 

responsibility to oversee and administer the program. 

7 The total amount does not include $6 million provided to the OIG to provide oversight over the 

Department’s recovery Act activities. 

Recovery Act: WIA Youth Program 

21		 Report No.18-11-006-03-390 
 

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Title VIII of the Recovery Act provided DOL with an additional $1.2 billion in WIA 

formula funds for youth employment and training activities. The Recovery Act also 

extended the youth eligibility age from 21 to 24. The Recovery Act allows states to 

spend additional WIA Youth Program funds on activities related to any of the 10 

program elements described in Section 129 of WIA. Because the Recovery Act allows 

DOL to retain one percent of the funds for program administration and oversight, the 

actual allotment to States was $1.188 billion. States have until June 30, 2011, to spend 

these additional funds. 

In March 2009, ETA issued two guidance letters on spending additional WIA formula 

funds provided by the Recovery Act. These include Training and Employment 

Guidance Letter (TEGL) 13-08 and on March 6, 2009 TEGL 14-08. TEGL 13-08 

(Attachment II) contained a list of State allotments for the WIA Youth Program under the 

Recovery Act. TEGL 14-08 provided information that states and Local Areas might 

consider in planning how to use additional WIA Youth Program funds. TEGL 14-08 also 

included instructions to states on submitting modified WIA Plan by June 30, 2009. ETA 

issued TEGL 24-08 on May 21, 2009, which provided guidance for reporting 

performance accountability for programs receiving additional funds under the Recovery 

Act. 

Recovery Act: WIA Youth Program 

22 Report No.18-11-006-03-390 
 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Appendix B 

Objectives, Scope, Methodology, and Criteria 

Objective 

The objectives of our audit were to determine: 

(1) How did Local Areas spend or how were they planning to spend their allocation of 

WIA Youth Formula Funds? 

(2) Who were the participants in the WIA Youth Program? 

(3) What services were participants in the WIA Youth Program receiving? 

(4) What were the outcomes for participants enrolled in the WIA Youth Program? 

(5) To what extent were employers using the Work Opportunity Tax Credit to hire 

disconnected youth (ages 16 to 24) as provided by the Recovery Act? 

Scope 

Our performance audit covered the period from February 17, 2009, to September 30, 

2010. We conducted our fieldwork at the ETA National Office in Washington, D.C., at a 

pilot LWIB in Louisville, Kentucky; through phone interviews, surveys and data 

collection instruments with 101 LWIBs, Statewide WIA youth activities, and INA 

grantees selected in a statistical sample. Our performance audit was not designed to, 

and we did not, perform a financial audit of the amounts obligated or expended at any of 

the LWIBs, Statewide WIA youth activities or INA grantees. 

We conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence 

obtained provided a reasonable basis for our findings and conclusions based on our 

audit objectives. 

Methodology 

To accomplish our audit objectives, we obtained an understanding of Title VIII of the 

Recovery Act, which provided DOL with an additional $1.2 billion in WIA formula funds 

for youth employment and training activities. The Recovery Act also extended the youth 

eligibility age from 21 to 24. The Recovery Act allows states and Outlying Areas and 

INA grantees to spend additional WIA Youth Program funds on activities related to any 

of the 10 program elements described in Section 129 of WIA. We also conducted 

interviews with ETA, State and LWIB officials in performing our work. The information in 

Recovery Act: WIA Youth Program 

23 Report No.18-11-006-03-390 
 

 

 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

this report was developed by DOL-OIG independent of ETA. The DOL-OIG is 

legislatively independent and charged with performing independent audit of DOL. Ollie 

Green and Company under contract with the DOL-OIG collected information directly 

from LWIBs, Statewide Youth Activities, and INA grantee officials in all 52 states and 

territories. 

Our methodology for this performance audit included the use of statistical sampling. The 

application of the sampling process was conducted in conjunction with the DOL-OIG 

statistician. The statistical sampling universe for our model was defined as LWIBs, 

Statewide WIA youth activities, and INA grantees. The audit covered the period from 

Recovery Act enactment through September 30, 2010. The 101 sampling units 

illustrated in Exhibit 1 from a universe of 830 accounted for 26.5 percent of total dollar 

value of Recovery Act funds allocated to the universe. Our sample test results were 

estimated to the universe by the DOL-OIG statistician. We determined our sample size 

of 101 units using a 95 percent confidence level and a precision of plus/minus 5 

percent. 

We performed a data reliability assessment to ensure we were receiving complete and 

accurate data in our surveys and DCIs. To determine whether data was reliable to 

select our sample, we met with the Unit Chief, Youth Policy and Performance Unit at the 

National Office to discuss controls over the processing and reporting of fiscal and 

performance data. To gain a better understanding of the processing and reporting of 

fiscal and performance information, we requested from ETA and received a description 

and flowchart of systems in place designed to ensure the integrity of data processed at 

the LWIB/INAs level. We used checklists to assess the integrity of the information 

received on each DCI received. If DCI information was questionable based on checklist 

requirements, we contacted the LWIB/INAs and requested clarification and/or 

modification of information received. We reviewed systems data validation checks, edit 

checks, report validation, data element validation and, batch totals and concluded that 

the data received from LWIB/INAs in their DCIs was sufficiently reliable for our audit 

purposes. 

We used a random sampling method with stratified design to provide effective coverage 

of the units to obtain precise estimates of the characteristics tested. Each unit was 

tested for multiple characteristics as discrete variables involving nominal measures. An 

explanation of the audit test results and relevance of the test to the audit’s objectives is 

provided in the body of the audit report. 

We used structured interviews, surveys and data collection instruments to perform our 

audit. The interviews were conducted during November 2010 through January 2011. 

We supplemented the data we gathered from LWIBs, Statewide WIA youth activities, 

and INA grantee officials and with publicly available data from DOL’s website at 

www.doleta.gov/recovery/ and other information provided by ETA. As a result, 

information in our report does not include nonpublic information, which LWIBs, 

Statewide WIA youth activities, and INA grantees may have provided to DOL. 

Recovery Act: WIA Youth Program 

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Prepared by Ollie Green & Company, CPA’s 

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A performance audit includes gaining an understanding of internal controls considered 

significant to the audit objectives, testing controls, and testing compliance with 

significant laws, regulations and other requirements. For this engagement, we obtained 

an understanding of ETA’s process for evaluating the integrity of fiscal and performance 

data submitted by States and Local Areas receiving Recovery Act formula funding. The 

testing of internal controls over this process was not determined to be significant to our 

audit objectives. 

Criteria 

We used the following criteria to accomplish our audit: 

•	 The American Recovery and Reinvestment Act of 2009; 

•	 Training and Employment Guidance (TEGL)Letter 13-08 dated March 8, 

2009, including Attachment II; 

•	 Training and Employment Guidance (TEGL) Letters14-08 dated March 18, 

2009; including Change. 

•	 Training and Employment Guidance (TEGL)Letter 24-08 dated May 21, 

2009; 

•	 Workforce Investment Act- Sections 126 through 129; 

•	 Workforce Investment Act – Final Regulations; 

•	 OMB Memorandum 09-15, Updated Implementing Guidance for the 

American Recovery and Reinvestment Act of 2009, April 3, 2009; 

•	 Federal Acquisition Regulations; 

• Federal Register; 

•	 Wagner-Peyser Act, as amended (29 U.S.C 49 et seq.) 

•	 20 CFR Part 667.210 

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Recovery Act: WIA Youth Program 

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Appendix C 

Acronyms and Abbreviations 

ARRA American Recovery and Reinvestment Act of 2009 

DCI Data Collection Instrument 

DOL Department of Labor 

ETA Employment and Training Administration 

LWIB Local Workforce Investment Board 

LWIB/INA Local Workforce Investment Board/Indian or Native American 

OG&C Ollie Green &Company, CPA’s 

OIG Office of Inspector General 

TEGL Training and Employment Guidance Letter 

WIA Workforce Investment Act 

WOTC Work Opportunity Tax Credit 

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Recovery Act: WIA Youth Program 

28 Report No.18-11-006-03-390 
 

u .s . Department of Labor 

MAR 2 2 1011 

MEMORANDUM FOR: 

FROM: 

SUBJECT: 

Assistant secretary lor 

Employment and Training 

Washington, D.C. 20210 

ELUOT P. LEWIS 

Assistant Inspector General for Audit 

Office of the Inspector General 

JANEOATFS 

Assistant Secretary 

~~ for Employment and Training 

Employm~nt and Training Administration 

Response to Draft Report Number: 18-11-006-03-390 

"Recovery Act: Workforce Investment Act Youth 

Program" 

We are pleased with the positive results of the audit entitled "Recovery Act: 

Workforce Investment Act (WIA) Youth Program." The audit report clearly 

demonstrates that the Employment and Training Administration (ETA) was able 

to effectively implement the Recovery Act WIA Youth activities funding 

provided by Congress. Your audit results also demonstrate that these funds will 

be fully spent and have been spent on their intended purpose, with the majority 

of funds spent on SUlmner employment and paid and unpaid work experiences. 

While ETA agrees with the audit results contained in the draft report, there are 

two minor changes required in the report's language in order to better convey 

factual information. First. on page one in the next to last sentence of the first 

paragraph, ETA recommends clarifying that the $1.188 billion allotment is for 

States as well as outlying areas and Indian and Native American (INA) 

programs. 

Second, on page two and eleven describing the requirements to track the Work 

Opportunity Tax credit (WOTC), ETA recommends clarifying that no 

LWIB/INAs were required to track the warc to hire disconnected youth. We 

recommend deleting the word "most" and replacing it with" although" so that 

the starement reads "Finally our audit founc.I that although LWIBjINAs were not 

required to track the warc ... 14 of the respondents surveyed indicated that 

they had implemented systems designed to track the ware used by 

employers." 

We appreciate the opportunity to review and comment on the draft report. 

Prepared by Ollie Green & Company, CPA’s 

for U. S. Department of Labor – Office of Inspector General 

Appendix D 

Employment and Training Administration Response to Draft Report 

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Recovery Act: WIA Youth Program 

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Appendix E 

Acknowledgements 

Key contributors to this report were Ollie Green, MBA, CPA (Managing Partner) Mr. 

Jerome Cooper (OIG Task Monitor), Susan Savitch, MS, CPA (Audit Manager), Andrea 

Morris, CPA (Audit Manager), Sharon Adams, CIA, CPA (Audit Manager), Nermina 

Mustafic (Staff Accountant), Elaine Styles (Staff Accountant). 

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Recovery Act: WIA Youth Program 

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TO REPORT FRAUD, WASTE, OR ABUSE, PLEASE CONTACT: 

Online:		 http://www.oig.dol.gov/hotlineform.htm 

Email:		 hotline@oig.dol.gov 

Telephone:		 1-800-347-3756 

202-693-6999 

Fax: 202-693-7020 

Address: Office of Inspector General 

U.S. Department of Labor 

200 Constitution Avenue, N.W. 

Room S-5506 

Washington, D.C. 20210