1. 1 Program and Compliance Management Opening Session: PERSPECTIVES ON ACCOUNTABILITY V I R T U A L L Y

2. Outline Key Attributes Your Compliance Playbook The Forest, The Trees and Performance Management The Zen of Reporting Data, Data Everywhere 2

3. INTRODUCTION Which of the following statements describes your thoughts/opinions about performance and performance data? A.I get warm fuzzies B.Performance accountability is my friend C.Id rather have root canal D.I dont think its meant to be understood E.Its something for techies, right? 3

4. Key Attributes of Accountability within the Framework of Program & Compliance Management 4

5. Universality Universality All levels, entities, individuals Relativity Relativity Its all relative for all of the above 5

6. Questions Based on the Universality and Relativity of Accountability Whats another way of saying The National Context? –The _i_ P_ _ t u _ _ –B_ _ _ nd the S _ _ _ es What does Isaac Newtons theory have to do with accountability? –Accountability flows ___________. 6

7. The National Context Government Performance & Results Act of 1993Government Performance & Results Act of 1993 –Applies to federal agencies but many implications for ___________ and ____________ –Primary purpose to inform Congressional decision- making and institutionalize results-driven government –Referenced often Funding decisions tied to performance outcomes based on solid data 7

8. Universal A Universal Accountability Framework PROGRAM & COMPLIANCE MANAGEMENT 8

9. Universal A Universal Accountability Framework Authorizing Statute with associated regs PROGRAM & COMPLIANCE MANAGEMENT 9

10. Universal A Universal Accountability Framework Authorizing Statute with associated regs 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 10

11. Universal A Universal Accountability Framework Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 11

12. Universal A Universal Accountability Framework Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars P.L. 107-288 (JVA) 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 12

13. Universal A Universal Accountability Framework ETA Policies Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars P.L. 107-288 (JVA) 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 13

14. Universal A Universal Accountability Framework ETA Policies GRANT AGREEMENT Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars P.L. 107-288 (JVA) 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 14

15. Universal A Universal Accountability Framework ETA Policies GRANT AGREEMENT SGA Solicitation for Grant Applications Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars P.L. 107-288 (JVA) 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 15

16. Universal A Universal Accountability Framework OMB-Approved Reporting ETA Policies GRANT AGREEMENT SGA Authorizing Statute with associated regs 2 CFR Formerly OMB Circulars P.L. 107-288 (JVA) 29 CFR PROGRAM & COMPLIANCE MANAGEMENT 16

17. Your Compliance Playbook 17

18. Remember the Compliance Hierarchy 1.Statute 2.Regulations 3.Policy 18

19. Playbook Contents Not An Exhaustive List! Statute –P.L. 105-220 (WIA) –P.L. 107-288 (JVA) Regulations –29 CFR Part 95 and Part 97 –29 CFR Part 37 –20 CFR Part 652, et al. (WIA Regs) –2 CFR Policy –Training and Employment Guidance Letters (TEGLs) –Training and Employment Notices (TENs) –http://wdr.doleta.gov/directiveshttp://wdr.doleta.gov/directives 19

20. State/Local Playbook Extras State legislation, regulations, policy guidance, and/or procedural guidance Federal Policy Guidance Federal Regs Federal Statutes Local Local leadership further defines policy and procedural guidance based on all of the above and as appropriate 20

21. Reflections Whats your playbook status? 21

22. The Forest, The Trees and Performance Management 22

23. Fill in the Blanks Performance _________ __________ Management 23

24. Performance Management as Forest …with lots of trees –Performance measurement –Data collection –Data analysis –Customer satisfaction surveying –Reporting results –Contract administration –Etc. Translation: Performance measurement is part of performance management – they are not synonymous 24

25. Who Cares? Perceptions drive behavior –The measurement aspect may be the purview of a few technical or MIS staff but the management aspect is everyones business – every staff person from the One-Stop greeter to the Executive Director So whose performance is it anyway 25

26. The Bottom Line From an organizational perspective (irrespective of level) were all responsible for grants management or program management or compliance management From an individual perspective (irrespective of level) were all responsible for performance management 26

27. The Zen of Reporting 27

28. A 10,000 Foot View Data collection, Data entry, State & Local Policies, State MIS Required data must be mapped according federal specifications and reported by the State through ETAs online system Quarterly Program Reports National Reports and Analyses 28

29. Every One Counts From secretary to Secretary Decisions, decisions... Data entry – Timely and Accurate Know your MIS If you think youre too small to make a difference, youve never been in bed with a mosquito 29

30. Program Reporting Summed Up Who Youre Serving What Theyre Getting With What Results 30

31. If its not reported, it never it never happened happened 31

32. The WIASRD Workforce Investment Act Standardized Record Data Individual records for current and former WIA participants submitted on quarterly basis Basis of WIA aggregate reporting TEGL 17-09 required for the first time quarterly records on participants, not just exiters –Affords unprecedented level of analysis 32

33. Quarterly WIASRD Submissions TEGL 17-09, 3/10/10, Page 2 With more timely detailed information, ETA will be able to perform more in-depth program analysis and assessment. Decisions will be better informed, and states will gain access to frequent updates on nationwide trends in participant characteristics, training, employment services, and outcomes. 33

34. Caution: The WIASRD isnt just for MIS, reporting or performance staff –Its the foundation for WIA accountability! (including data validation) –It contains information program staff need (like definitions and their nuances) Some states put key aspects of the WIASRD into state program guidance (e.g., eligibility) 34

35. Data, Data Everywhere 35

36. Context is Critical The bad news is, you do less work than anyone in this office. The good news is, you make the fewest mistakes. 36

37. Garbage In Garbage Out The government is very keen on amassing statistics. They collect them, add them, raise them to the nth power, take the cube root, and prepare wonderful diagrams. But you must never forget that every one of these figures comes in the first instance from the village watchman, who just puts down what he pleases. Question: Whos the village watchman? 37

38. Caveat Emptor Know the context and be an informed consumer of information Our data tell a story; Your data tell a story …so what does it say? 38

39. About The Workshops in this Conference Information that supports workforce development accountability, compliance and data management –Findings/Concerns from data validation reviews highlighted –National, Regional, State, Local WIASRD data discussed –Etc. 39

40. Weve Only Just Begun! 40

41. Accountability: A Universal Framework Program & Compliance Management Authorizing Statute 29 CFR OMB Circulars (2 CFR) Approved Reporting Instructions Grant Agreement SGA Jobs for Veterans Act ETA Policies Appendix

42. Authorizing Statute –In most cases, the Workforce Investment Act or WIA is the authorizing statute (Sec. 171 of WIA authorizes pilot and demonstration projects). Note that the WIA regulations would apply. –Earmark grants are authorized by appropriations legislation 29 CFR (Code of Federal Regulations) –Parts 95 and 97 contain uniform administrative requirements (e.g., grantees are responsible for managing their projects, including sub-recipient activities and services; includes requirements pertaining to data collection and reporting) –Part 37 contains implementing regulations for the non-discrimination and equal opportunity provisions of WIA Sec. 188 OMB Circulars –Includes cost principles (e.g., OMB Circular A-21 covers institutions of higher education) –Circulars now codified under 2 CFR Jobs for Veterans Act –Public Law 107-288 pertains to all DOL-funded employment and training programs and establishes priority of service for veterans and eligible spouses ETA Policies –Training & Employment Guidance Letters (or TEGLs) covering a range of topics, including salary and bonus limitations (TEGL 5-06) and the definitions of key terms such as participant and exiter contained in TEGL 17-05 SGA (Solicitation for Grant Application) –Contains grant-specific and/or program-specific information; grantees agree to provisions as condition of award receipt. (The SGA could clarify that certain activities and/or expenditures are unallowable for the particular grant.) Grant Agreement –This is the agreement between USDOL and the grantee organization. It contains the Statement of Work (SOW) and performance expectations Approved Reporting Instructions –The OMB-approved ETA 9130 is required of all USDOL/ETA grantees for quarterly financial reporting –Programmatic reporting is different across the core workforce programs (different reports for Wagner-Peyser and WIA) and it also differs across discretionary grantees (based on OMB-approved reporting instructions for the specific type of grant).