Iowa Administrative Code › Agency 877 - Workforce Development Board and Workforce Development Center Administration Division › Chapter 7 - Iowa Workforce Investment Act Program › Rule 877-7.21 - Compliance Review System

Current through Register Vol. 47, No. 3, July 24, 2024
The department shall conduct annual financial, program, and
				quality reviews.
(1)
Financial
			 compliance reviews.
An annual financial compliance review shall be
			 conducted by the department. The on-site reviews will be of all programs
			 administered through written agreement between the department, the
			 subrecipient, and the fiscal agents. Monitoring of non-fiscal agent entities
			 will be limited to those subcontractors of the department that receive $100,000
			 or more during the fiscal year. The monitoring will be performed to ensure
			 compliance with, but is not limited to, federal and state laws and regulations,
			 the workforce development center system handbook, welfare-to-work handbook,
			 contractual agreements with the department, and generally accepted accounting
			 principles, memorandum(s) of understanding, resource sharing agreements and
			 cost allocation plans.
(2)
Program compliance reviews.
An annual program compliance
			 review shall be conducted by the department. The reviews will focus on the
			 designated service providers for various programs. The on-site reviews include,
			 but are not limited to, the following: activities and services; applicant and
			 participant processes; participant eligibility; participant file review;
			 procurement procedures; management information systems; local plans; and
			 verifications of program performance. The review will ensure local compliance
			 with the applicable state and federal laws and regulations.
(3)
Initial determination.
Separate initial determination letters are completed for each on-site visit.
			 The report shall include a description of findings, which includes specific
			 references to the standards, policies or procedures which have been violated;
			 if necessary, recommended and required corrective action to be implemented by
			 the contractor, designated service provider or coordinating service provider; a
			 description of any questioned costs, including the amount; and time frames for
			 completing any corrective action and responding to the initial report.
			 Responses to the initial determination letter shall be submitted to the
			 department within 20 days from the date of receipt of the letter.
(4)
Final determination.
A
			 final determination letter shall be issued to the subrecipient within 20 days
			 after receipt of the response from the fiscal agent. The letter shall state the
			 department's determination on all findings that required a response and the
			 notification of the right to appeal the final determination. If any findings
			 are unresolved or if costs are disallowed, the letter shall also include a
			 description of the unresolved finding(s); a citation or reference to the
			 applicable regulations or policies on which the finding was based; the final
			 determination of the department on each unresolved finding; and, if there are
			 disallowed costs, the amount of costs disallowed and notification that an
			 initial demand letter shall be sent. Copies of the final determination letter
			 shall be sent to each region's regional workforce investment board, chief
			 elected official board, and coordinating service provider chairs.
(5)
Follow-up.
Follow-up on
			 findings identified shall be conducted during the following fiscal year's
			 review. The department's follow-up will review corrective actions taken in
			 response to those findings.
(6)
Appeals.
The subrecipient may submit an appeal of a final
			 determination within ten days of receipt of the final determination. The appeal
			 may be on behalf of a designated service provider, coordinating service
			 provider or the fiscal agent. The appeal must be directed to the Division
			 Administrator, Division of Workforce Development Center Administration,
			 Department of Workforce Development, 150 Des Moines Street, Des Moines, Iowa
			 50309. The request for an appeal must also include a copy of the final
			 determination and the basis for the appeal. Appeals shall be reviewed by a
			 three-member appeal committee which shall include one staff member from three
			 different bureaus in the department. Appeals shall be reviewed by staff not
			 actually involved in the on-site monitoring that resulted in the original
			 finding and subsequent final determination. A decision on the appeal shall be
			 rendered by a majority vote of the appeal committee. If the appeal committee
			 cannot arrive at a decision, the division administrator shall make the final
			 decision.
(7)
Quality
			 reviews.
The department shall conduct annual quality reviews. The
			 reviews will focus on overall workforce development center system performance,
			 customer satisfaction, and continuous improvement.
a. System performance measures will be
			 reviewed with the coordinating service provider to identify areas of strength
			 and areas that may need improvement. The review will include an interview with
			 the required workforce development center system partners individually or the
			 partners as a group, or both. The regional customer service plan will also be
			 reviewed to determine what progress is being made to meet the needs and
			 priorities identified by the regional workforce investment board and chief
			 elected official board. In the event system performance standards are not being
			 met, the objective of the review will be to help identify methods for
			 improvement. Should the same issues be identified for two consecutive years, a
			 corrective action plan will be required by the department. All other issues
			 will be referred to the regional workforce investment board for its
			 action.
b. The memorandum(s) of
			 understanding between the workforce development center system partners and the
			 regional workforce investment board will be reviewed. The purpose is to ensure
			 that the products and services offered through the system are available,
			 accessible, and being used.
c. The
			 review will look at efforts being made to coordinate workforce development
			 services throughout the region, to build new partnerships, and to assess the
			 results of these efforts. This may include, but is not limited to, joint grant
			 applications, efforts to integrate services and minimize duplication from the
			 system, level of participation in the system by required and voluntary
			 partners, and unique funding or service delivery methods involving multiple
			 service providers.
d. Overall
			 customer satisfaction of the workforce development center system is to be
			 evaluated. Randomly selected program participants and employers identified in
			 the common intake system will be interviewed. The interview will include, at a
			 minimum, a review of the customer's file as presented on the common intake
			 system, the customer's overall perception of how the customer was treated, an
			 evaluation of the services offered as compared to the needs of the customer,
			 and a review of the case file with the case manager.
e. An exit interview to review the findings
			 will be conducted with the regional workforce investment board and coordinating
			 service provider. Methods for improving systems will be discussed and an
			 agreement reached on their implementation. The coordinating service provider
			 will have 14 days to respond to the findings and recommendations, at which time
			 a final report will be prepared and delivered to the chair of the regional
			 workforce investment board.