TEGL_23-19_Acc.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION WIOA CORRESPONDENCE SYMBOL OPDR DATE June 18 2020 RESCISSIONS TEGL 22-15 EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 23-19TO STATE AND LOCAL STAKEHOLDERS IN THE WORKFORCE INNOVATION AND OPPORTUNITY ACT STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS H-1B JOB TRAINING PROGRAM GRANT RECIPIENTS INDIAN AND NATIVE AMERICAN PROGRAM INAP GRANT RECIPIENTS JOB CORPS CONTRACTORS JOBS FOR VETERANS STATE GRANTS JVSG GRANT RECIPIENTS STATE MONITOR ADVOCATES NATIONAL FARMWORKER JOBS PROGRAM NFJP GRANT RECIPIENTS NATIONAL DISLOCATED WORKER GRANT RECIPIENTS DWG REGISTERED APPRENTICESHIP PROGRAMS REENTRY EMPLOYMENT OPPORTUNITIES REO GRANT RECIPIENTS SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM SCSEP GRANT RECIPIENTS TRADE ADJUSTMENT ASSISTANCE TAA LEADS YOUTHBUILD GRANT RECIPIENTS FROM JOHN PALLASCH s Assistant Secretary SUBJECT Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor DOL Workforce Programs 1.Purpose. This guidance provides information to grant recipients of the U.S. Department of Labor workforce programs including states and provides guidelines for grant recipients to use in developing procedures for ensuring the data submitted for performance reporting are valid and reliable. 2.Action Requested. Grant recipients should distribute this information to the appropriate staff. 2 3.Summary and Background. A.Summary. This guidance is specific to grant recipients of DOL workforce programs and aligns with and expands on the DOL Department of Education Joint Guidance in Training and Employment Guidance Letter TEGL 7-18 Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act WIOA . This guidance provides specific data validation guidance for the WIOA core programs and other DOL-funded programs not addressed in TEGL 7-18. B.Background. Data validation is a series of internal controls or quality assurance techniques established to verify the accuracy validity and reliability of data. The establishment of a shared data validation framework that requires a consistent approach across programs ensures that all program data consistently and accurately reflect the performance of each grant recipient. To that end the purposes of validation procedures for both DOL-only and jointly-required performance data are to Verify that the performance data reported by grant recipients to DOL are valid accurate reliable and comparable across programs Identify anomalies in the data and resolve issues that may cause inaccurate reporting Outline source documentation required for common data elements and Improve program performance accountability through the results of data validation efforts. This issuance provides additional DOL-specific guidance on data validation for DOL programs including those that are not WIOA core programs referred to in this guidance as non-core programs as well as additional DOL-specific guidance on the DOL- administered WIOA core programs. Non-core programs include programs authorized by WIOA as well as programs authorized by other Federal legislation. Collectively the non-core programs include Indian and Native American INA Program under WIOA section 166 Job Corps under WIOA sections 141-162 National Farmworker Jobs Program NFJP under WIOA section 167 YouthBuild under WIOA section 171 Reentry Employment Opportunities REO authorized under WIOA section 169 National Dislocated Worker Grants DWG under WIOA section 170 H-1B Job Training Programs grants awarded July 1 2016 and later authorized under section 414 c of the American Competitiveness and Workforce Improvement Act of 1998 29 U.S.C. 3224a Senior Community Service Employment Program SCSEP authorized under title V of The Older Americans Act of 1965 42 U.S.C. 3056 et seq. Trade Adjustment Assistance TAA authorized under chapter 2 of title II of the Trade Act of 1974 19 U.S.C. 2271 et seq. 3 Apprenticeship Program Grants administered by the Office of Apprenticeship and Jobs for Veterans State Grants JVSG authorized under 38 U.S.C. chapter 41. In addition the data validation requirements in this guidance also apply to the Monitor Advocate System. The Monitor Advocate System protects the standard of services provided to migrant and seasonal farmworkers MSFWs under the Wagner-Peyser Act Employment Service program. Therefore as part of a WIOA Core Program all of the requirements that apply to the Wagner-Peyser Act Employment Service for data validation will apply to the Monitor Advocate System. DOL jointly with the Department of Education issued TEGL 7-18 Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act WIOA which elaborated on the data validation guidelines for performance accountability required under WIOA section 116 d 5 . This DOL-only data validation guidance fits within the framework established in TEGL 7-18 and provides DOL grant recipients with additional details on the framework for data validation. Grant recipients must develop data validation policies and procedures consistent with the instructions in this guidance. 4.DOL Data Validation Requirements. A.Requirements for WIOA Core Programs and Non-Core Programs. WIOA Core Programs and the TAA program WIOA establishes performance accountability indicators and performance reporting requirements to assess the effectiveness of states and local areas in achieving positive outcomes for individuals served by the workforce development system s six core programs. WIOA core programs as well as the TAA program Sec. 239 j 3 of Trade Act of 1974 are required to follow the data validation framework outlined in section B as well as any program specific guidance outlined in Attachment I. Other Non-Core Programs Other non-core programs are required to follow the program-specific guidance related to data validation discussed in Attachment I. To meet the objectives of accurate valid and reliable program data these non-core programs are highly encouraged to also implement the data validation framework outlined below. B.Data Validation Framework. The WIOA Core programs and the TAA program must use a data validation strategy. However these programs and the other non-core program grant recipients have the discretion to decide the specific design implementation and periodic evaluation of that strategy so long as those strategies or procedures adhere to this guidance. Data validation helps ensure the accuracy of quarterly and annual performance reports safeguards data integrity and promotes the timely resolution of data anomalies and 4 inaccuracies. As such it is recommended that grant recipients incorporate their data validation procedures and methodology into their internal controls data quality assurance process and the 2 CFR 200.328-required monitoring policies and procedures. WIOA core programs and the TAA program must develop data validation procedures that include Written procedures for conducting data validation reviews that contain a description of the process for identifying and correcting errors or missing data which may include electronic data checks Regular data validation training for appropriate program staff DOL recommends at least annually Monitoring protocols consistent with 2 CFR 200.328 to ensure that program staff are following the written data validation policy and procedures and take appropriate corrective action if those procedures are not being followed A regular data integrity review of program data DOL recommends quarterly for errors missing data out-of-range variances in values reported and other anomalies Documentation that missing and erroneous data identified during the review process have been corrected Documentation processes for maintaining records per the Federal records retention policy on results which may include copies of worksheets on data elements or records reviewed frozen quarterly wage records for wage record matching used for reporting outcomes trends in common data accuracy issues error rates and corrective action efforts made after data validation reviews and Regular assessments of the effectiveness of the data validation process DOL recommends at least annually and revisions to that policy and process as needed. On a quarterly basis DOL will be providing grant recipients with feedback regarding their performance reports to aid in data integrity efforts and support data accuracy. The analysis will include but is not limited to a review of the data submitted anomalies and outliers and other potential data quality issues which may indicate reporting inaccuracies. Grant recipients are encouraged to incorporate the DOL s analysis into their data validation processes. For the WIOA Core programs the information in the State s annual report must be validated before it is submitted to DOL. However DOL recommends that all grant recipients engage in data validation activities on a quarterly basis to ensure their data is accurate. Establishing q uarterly data reviews is a best practice for identifying and correcting errors to improve performance reporting and ensuring the data properly reflects the program participants services and outcomes . C.Data Validation Parameters. Policies and procedures developed by the WIOA Core programs as well as the TAA program must include regular data element validation through program monitoring on the specific data elements required in TEGL 7-18 and Attachment II of this TEGL. DOL selected the elements in Attachment II based on their 5 importance to reporting accurate performance outcomes and to ensure data consistency across the programs mentioned above in section 3B. DOL will not be providing a specific statistical validation sampling methodology or specific data validation software. However grant recipients are encouraged to incorporate a comprehensive random sampling methodology and procedure for the source documentation review of participant files into their data validation processes. Grant recipients using a random sampling methodology should provide a sufficient representation of records from each program and for each of the required elements that may be specific to the respective program.1 1 Grant recipients may use publicly available calculators and tools for determining sample size based on total records. D. Source Documentation. In Attachment II of this guidance programs mentioned above in section 3B identify acceptable source documentation necessary to validate these selected data elements. Grant recipients may 1 maintain supporting source documentation for program-specific data elements not included in this guidance 2 conduct source document validation on additional data elements and or 3 require additional source documentation in their procedures. DOL recommends that grant recipients identify similar data elements that are required for validation such as for eligibility documentation and use those requirements as a basis for developing source documentation requirements for any additional elements beyond the requirements set forth in Attachment II. E.Reporting Requirements. Grant recipients must describe their data integrity measures data validation methodology policies and procedures as required by their individual program guidance in Attachment I. Grant recipients should contact their appropriate regional or program offices for technical assistance. F.Monitoring. DOL s monitoring of these requirements will be conducted by the appropriate regional or program office. During these reviews grant recipients can expect Federal staff to conduct monitoring activities that includ e but are not limited to 1 checking for data validation policies processes and procedures 2 verifying staff are being trained and if any corrective action is needed or implemented 3 reviewing files and source documentation 4 reviewing data validation results maintained per Federal records retention policy and 5 analyzing data integrity reports generated by DOL. Reviews may result in findings or requirements for corrective action. 6 5.Inquiries. Please direct inquiries to the appropriate regional or program office. 6.References. Please see Attachment III. 7.Attachment s . Attachment I Program Specific Instructions Attachment II Source Documentation for WIOA Core Non-Core Programs Attachment III References