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State OJT Monitoring Guide


Attachment 2 - DLLR/DWDAL

State On-the-Job Training (OJT) Monitoring Guide

Monitoring Purpose and Process

Oversight and monitoring of the Workforce Investment Act (WIA) on-the-job training (OJT) is conducted to ensure compliance with applicable laws and regulations, ensure the integrity of WIA funds and the WIA system, review performance, and identify successful methods and practices that can, when shared, serve to enhance continuous improvement of the OJT and the system as a whole. 

The state OJT monitoring process is accomplished through a combination of desk and on-site reviews of its local areas or subrecipients.  Each is explained in detail below. 

To the extent practical, the OJT monitoring of local areas or subrecipients should be scheduled in conjunction with other on-site OJT component reviews, so as to minimize disruptions to operations. If the OJT, financial and performance review functions are conducted by separate individuals, these staff should, to the degree possible and appropriate, coordinate the schedule of on-site monitoring reviews.

Monitoring Scope and Frequency

State monitoring of local areas or subrecipients OJT operations should be conducted on-site at least annually for the WIA IB Adult, Dislocated Worker, and Youth programs.  These should include the use of the OJT Review Guide below, and should cover:  a sample review of OJT contracts to ensure compliance with Federal and state guidance for the WIA OJT; and should also include a review of the monitoring conducted by the local area or subrecipient of its own OJT operations. 

Monitoring Procedures

Monitoring procedures and instructions for OJT on-site reviews are presented below.  If the OJT review is conducted in conjunction with other OJT components, this will be done for all components being reviewed.

A. Monitoring Review Set Up

  1. Contact the local area or subrecipient to obtain a monitoring date and advise them of the scope of the OJT monitoring review.  A copy of this Monitoring Guide can be provided to the local area or subrecipient in advance of the review.
  2. If requested, prepare and transmit a letter confirming the date and scope of the review send or email it to the Director.
  3. Telephone or email the contact person one day prior to the start date of visit as a reminder.

 

B. Entrance Conference

  1. Arrange for an entrance conference.  However, a formal entrance conference is not always necessary.  The decision to have an entrance conference should be a mutual one between the local area/subrecipient and monitor.  Instances where an entrance conference would be necessary are:
  1. This is the initial OJT monitoring visit to the local area/subrecipient.
  1. There are major problems with the local area��s/subrecipient's financial or program systems.
  2. An entrance conference is requested by the local area/subrecipient.
  1. When an entrance conference is held, the local area��s/subrecipient��s executive director and other appropriate staff (at the discretion of the executive director) should attend.  The monitor can request specific staff be in attendance if there are programmatic reasons.
  1. The entrance conference may include, but should not be limited to the following subjects:
  1. The purpose of the visit.
  1. The procedures to be used by the monitor.
  2. Problems disclosed during prior review visits.
  1. Create a record of the meeting in the monitoring report (described below) prepared as result of the visit.

C. Sampling Procedures

Since it is rarely cost effective to examine all transactions, the monitor should consider whether examining a representative sample or cross-section of the items that make up the various classes of transactions in the review.   For an OJT review, this would include reviewing a number of employers, contracts and the related files, participant files (both currently in training and completed training), and local area/subrecipient monitoring reports.  In local areas where there are only a few OJT contracts or referrals to contracts, the monitor may need to review all files in order to get a good picture of how well the OJT is operating. The State should consider whether it will set policy to determine sample size in OJT reviews.  

If the OJT review is conducted in conjunction with other components, sampling of OJT participant files may be included as part of the sampling done for participants in all components being reviewed. In any case, the monitor must ensure the sample reviewed is sufficient to establish a pattern upon which findings and corrective action can be based.  While it is not critical that a statistically valid sample be used for during every OJT monitoring visit, combining statistical sampling with good monitoring judgment will generally produce a higher-quality monitoring conclusion than using monitoring judgment alone.  The monitor should review sufficient files to ensure the conclusions reached can be reasonably expected to be accepted based on the numbers reviewed.  This will be particularly important if the monitor encounters significant problems.  In the end, the monitor must make judgments about what represents usable sample and what additional work (e.g. increasing the sample size) may need to be performed if that rate is exceeded.

 

D. Technical Assistance

While each situation is unique and there are no set procedures to follow for providing technical assistance, the monitor must determine what is appropriate in the given circumstances.  Nonetheless, identifying an issue without providing accompanying technical assistance in the creation and implementation of corrective action may result in little improvement.  All technical assistance given should be documented in the work papers, and should be noted in summary in the monitoring report following the on-site visit.   Any necessary follow-up assistance should also be detailed in the work papers and noted in the monitoring report as well.

E. Exit Conference

  1. An exit conference is to be held at the end of every on-site review.
  2. In arranging the time for the exit conference, the monitor should ensure to the extent possible that the local area��s/subrecipient��s Executive Director and appropriate staff are available to attend. 
  3. Subjects discussed at the exit conference may include, but are not limited to:
  1. Findings disclosed during the review.
  1. Action taken to resolve prior findings.
  2. Required corrective action and timeframes.
  3. Technical assistance provided or to be provided by the monitor.
  4. Timeframes for issuance of the written monitoring report.
  1. Open discussions should be encouraged at the meetings. 
  1. The monitor will create a record of the meeting in the work papers and subsequently in the monitoring report.

F. Monitor��s Work Papers

Monitoring work papers record the activities that took place during the monitoring visit and form the rationale for the monitoring report.  Extensive notes may be necessary as part of the review process and may serve to validate the information collection process.  Monitoring work papers should:

  1. Detail the source of the information acquired and conclusions reached.
  2. Document the weaknesses and deficiencies disclosed by the review.
  3. Be complete, timely and fully reflect the review steps taken by the monitor.
  4. Be available for a supervisory review.
  5. Be retained as part of the local area��s/subrecipient��s file.

 

G. Monitoring Report

When the on-site monitoring review has been completed and the work papers have been fully prepared, a report must be written reflecting the purpose and scope of the review.  Again, if the OJT review is conducted in conjunction with other OJT component reviews, the OJT portion may be included in the overall report, which will include all components reviewed. 

The report should clearly identify all findings and required corrective action, and should set a timeline by which the local area/subrecipient is expected to complete each required corrective action.  The report may include instruction to the local area/subrecipient to submit written certification that corrective action has been completed. Written monitoring reports should be structured to assist the local area/subrecipient in reaching their goals by providing feedback to them regarding OJT, financial, compliance and performance issues.   

Any findings identified in the written monitoring report should reflect a concise statement of fact and should include the following information: the basis of the requirement in law, regulations, state policy or guidance, or Local Workforce Investment Board (LWIB) policy; any pertinent background information; problem analysis; a synopsis of what was reviewed;  size of the sample taken (if applicable); conclusions reached; and  recommendations for corrective action including timeframes. 

Preparation of the report and supervisory review should ideally be done within (insert applicable # for your state) days of the exit meeting.  The report should be issued to the local area��s/subrecipient��s Executive Director within (insert applicable # for your state) days of the review's exit meeting.  If reasons exist such that the report cannot be issued within this timeframe, the work papers should detail these reasons.  The LWIB Director and Chief Local Elected Official (CLEO) should be copied on any monitoring report issued to a local area/subrecipient.  For this purpose, significant findings are defined as those findings that:  may have a material impact on the financial reports which the Local Workforce Investment Area (LWIA) submits to the State; may materially impact the ability of the LWIA to meet established OJT performance measures; or represent a substantial violation of WIA statutory and regulatory requirements.

H. Desk Review

Desk reviews are used for collecting and analyzing information and to support on-site reviews/monitoring.  Desk reviews analyze existing data such as required OJT contracts, budgets, monthly financial and progress reports, any prior audits and monitoring reports.  The monitor should gather all current data available, written policy and procedures or other guidance governing the contracts, systems, and OJTs being reviewed.  Desk reviews may include telephone and/or e-mail contacts with staff at the entity being reviewed, or other entities that may have relevant information that could impact the desk review.  Given that OJT contracts are typically short in duration, it is appropriate to conduct an initial desk review within the first 30-60 days of the training period. If issues are detected during the desk review process, the monitor should be prepared to provide on-site technical assistance related to the issues disclosed. 

The monitor should become familiar with the LWIA plan for OJT, including any goals established for the OJT as part of the area��s overall economic development strategy.  The monitor should know what measures the LWIA has chosen to chart its progress toward those goals. 

The monitor should complete the Desk Review found at Attachment 1 of this Guide.

I. On-site Review

On-site reviews are the primary component of monitoring, using data collection techniques and this formal monitoring guide.  On-site reviews should be conducted per a monitoring schedule, and should serve to ensure local areas/subrecipients are operating OJT in accordance with their agreement with the State, and verify any findings or issues identified during the desk review.  Additional on-site reviews may be conducted beyond those on the schedule on an as-needed basis, should issues arise that require immediate or continuing attention.  The monitor should be prepared to provide on-site technical assistance during the conduct of an on-site review. 
 

Disclaimer: The tools, templates, and information provided in the OJT Toolkit serve as a general guide for states and local areas. Although every effort is made to ensure that the material within this web site is accurate and timely, we make no warranties or representations as to the accuracy or completeness of the contents, whether the contents are current, or free from changes caused by third parties. All information is provided ��as is�� without warranty of any kind. No information provided in this site may be considered legal advice and it is the responsibility of each user of the OJT Toolkit materials to ensure that the materials meet all federal, state and local requirements. Use of the materials does not imply compliance with ETA requirements. 

 

Attachment 1

OJT Monitoring Guide DESK REVIEW

 
    LWIA:
    MONITOR:
    DATE OF DESK REVIEW:
  ISSUE OR QUESTION   NOTES / DISCUSSION
1 Has the LWIA established clear and concise on-the-job training (OJT) policies and procedures?

(The monitor should obtain a copy and review prior to going on-site.)

YES NO  
2 Do the LWIA policies and procedures clearly set requirements and/or standards for OJT contracting, payments, monitoring and evaluation?

(The monitor should note any areas in question for further examination on-site.)

YES NO  
3 Has the LWIA established clear goals for its OJT?

(The monitor should obtain a copy and review prior to going on-site.)

YES NO  
4 Does it appear that the LWIA is on track to meet its annual objectives for its OJT? 

(The monitor should review quarterly reports for OJT activity to assess probability.)

YES NO  
5 Does the LWIA plan target specific industry sectors or focus on skills common across various industry sectors for its OJT?

(The monitor should list these and then review employer contracts on-site to determine if the LWIA is meeting its plan.)

YES NO  
6 Has the LWIA submitted accurate and timely reports for its OJTs? 

(The monitor should obtain a copy and review prior to going on-site and if there have been problems should pursue reasons on-site.)

YES NO  
7 Has the LWIA organized and staffed its OJT operation at a level to meet its goals for OJT?

(The monitor should attempt to determine this before going on-site; if not possible, should get the information once on-site.)

YES NO  
8 List any areas of particular concern identified in the Desk review that must be further explored during the on-site visit.    

 

Attachment 2

 

OJT Monitoring Guide ON-SITE REVIEW

 
    LWIA:
    MONITOR:
    DATE OF DESK REVIEW:
  ISSUE OR QUESTION   NOTES / DISCUSSION
1. EMPLOYER ELIGIBILITY

(The monitor should review a sufficient sample of employer contracts and supporting documents to be able respond to the questions below.)

  (If there is insufficient space in this column, the monitor should attach notes, numbered in accord with this form.)
1.a. Do contracts show LWIA is targeting industries and occupations in the LWA plan? ☐ YES ☐ NO  
1.b. Is the LWIA recruiting employers in numbers sufficient to meet its plan? ☐ YES ☐ NO  
1.c. Does the LWIA use a pre-award review to determine employer eligibility prior to contract award? ☐ YES ☐ NO  
1.d. Are OJT contracts directed at employers who are able to provide occupational skill training? ☐ YES ☐ NO  
1.e. Are employers required to hire first and then to train eligible participants, and are all OJT trainees employees of the OJT contracting employer, rather than independent contractors or contract employees? ☐ YES ☐ NO  
1.f. Does the LWIA require certification by the employer, or otherwise assure the employer is in good standing and eligible for an OJT contract? ☐ YES ☐ NO  
1.g. Does the OJT Agreement format assure that:    
1.g.1.
  • No funds provided to employers for OJT are used to directly or indirectly assist, promote, or deter union organizing?
☐ YES ☐ NO  
1.g.2.
  • That WIA funds are not used or proposed to be used for the encouragement or inducement of a business, or part of a business, to relocate from any location in the United States, until the company has operated at that location for 120 days, if the relocation results in any employee losing his or her job at the original location?
☐ YES ☐ NO  
1.g.3.
  • The OJT contract does not impair existing contracts for services or collective bargaining agreements, and that if, as an OJT authorized under title I of WIA, the OJT would be inconsistent with a collective bargaining agreement, the OJT obtains written concurrence from the appropriate labor organization and employer before the OJT activity begins?
☐ YES ☐ NO  
1.g.4.
  • No participant in WIA OJT displaces (including a partial displacement, such as a reduction in the hours of non-overtime work, wages, or employment benefits) any currently employed employee (as of the date of the participation)?
☐ YES ☐ NO  
1.g.5.
  • No OJT participant in an OJT under title I of WIA is employed in or assigned to a job if any other individual is on layoff from the same or any substantially equivalent job?
☐ YES ☐ NO  
1.g.6.
  • No OJT participant in an OJT under title I of WIA is employed in or assigned to a job if the employer has terminated the employment of any regular, unsubsidized employee or otherwise caused an involuntary reduction in its workforce with the intention of filling the vacancy so created with the WIA participant any other individual is on layoff from the same or any substantially equivalent job?
☐ YES ☐ NO  
1.g.7.
  • No OJT participant in an OJT under title I of WIA is employed in a job which is created in a promotional line that infringes in any way on the promotional opportunities of currently employed workers?
☐ YES ☐ NO  
1.g.8.
  • Regular employees and OJT participants alleging displacement because of and OJT participant may file a complaint under the applicable grievance procedures found at 20 CFR 667.600 and WIA section 181?
☐ YES ☐ NO  
1.g.9.
  • Individuals in OJT under title I of WIA are compensated at the same rates, including periodic increases, as trainees or employees who are similarly situated in similar occupations by the same employer and who have similar training, experience and skills, and that such rates are in accordance with applicable law, but may not be less than the higher of the rate specified in section 6(a)(1) of the Fair labor Standards Act of 1938 (29 USC 206(a)(1)) or the applicable State or local minimum wage law?
☐ YES ☐ NO  
1.g.10.
  • Individuals in OJT under title I of WIA are provided benefits and working conditions at the same level and to the same extent as other trainees or employees working a similar length of time and doing the same type of work?
☐ YES ☐ NO  
1.g.11.
  • That health and safety standards established under Federal and State law otherwise applicable to working conditions of employees are equally applicable to working conditions of OJT participants in engaged in activities under Title I of WIA?
☐ YES ☐ NO  
1.g.12.
  • To the extent that a State workers' compensation law applies, workers' compensation are provided to OJT participants in OJTs under Title I of WIA on the same basis as the compensation is provided to other individuals in the State in similar employment?
☐ YES ☐ NO  
1.g.13.
  • OJT participants receive the benefit of non-discrimination and equal opportunity requirements and procedures, including complaint processing and compliance reviews, as governed by the regulations implementing WIA section 188, codified at 29 CFR part 37, and administered and enforced by the DOL Civil Rights Center?
☐ YES ☐ NO  
1.g.14.
  • The employment or training of OJT participants in sectarian activities is prohibited, except with respect to the maintenance of a facility that is not primarily or inherently devoted to sectarian instruction or religious worship, in a case in which the organization operating the facility is part of an OJT activity providing services to participants?
☐ YES ☐ NO  
1.h. FINAL QUESTION:  Is the LWIA administering its Employer Recruitment and Pre-Screening OJT in compliance with Federal and State requirements, and with its own policies and procedures?   Summarize any issues: ☐ YES ☐ NO  
2. PARTICIPANT SUITABILITY FOR OJT AND THE REFERRAL PROCESS

(The monitor should review a sufficient sample of participant files and supporting documents, and should interview LWIA staff as necessary, to be able respond to the questions below.)

   
2.a. Does a review of OJT participant files in the LWIA verify that:    
2.a.1.
  • LWIA procedures clearly set guidelines and processes to establish the suitability of trainees referred to specific OJT employers?
☐ YES ☐ NO  
2.a.2.
  • The Individual Employment Plan (IEP) is established and identifies the use of OJT as appropriate to reach the trainee��s employment goals and achievement objectives prior to referral of the participant to the OJT employer?
☐ YES ☐ NO  
2.a.3.
  • Core and intensive services are provided prior to referral to OJT? 
☐ YES ☐ NO  
2.a.4.
  • An in-depth assessment of the participant��s occupational and academic skills as well as their prior work experience, interests and abilities occurs prior to referral to OJT? 
☐ YES ☐ NO  
2.a.5.
  • Procedures are in place and employed individuals are only referred to OJT as appropriate?
☐ YES ☐ NO  
2.a.6.
  • Youth are referred to OJT opportunities only when appropriate, i.e., when the youth training plan identifies employment goals and achievement objectives supporting the use of OJT?
☐ YES ☐ NO  
2.a.7.
  • The LWIA has a process and criteria to explore whether the referral of the individual to the employer is likely to be a good job match?
☐ YES ☐ NO  
2.a.8. FINAL QUESTION:  Is the LWIA administering its process for determining the suitability of participants and referring individuals to OJT in compliance with Federal and State requirements, and with its own policies and procedures?

Summarize any issues:

☐ YES ☐ NO  
3. OJT ADMINISTRATION

(The monitor should review a sufficient sample of participant files and supporting documents, and should interview LWIA staff as necessary, to be able respond to the questions below.)

   
3.a. Does a review of OJT files and reports, and discussion with OJT staff in the LWIA verify that:    
3.a.1.
  • The OJT provider has established an organizational structure that supports the mission established for the OJT within the overall economic development objectives of the area?
☐ YES ☐ NO  
3.a.2.
  • The provider has trained its OJT staff so as to assure the objectives of the OJT are met, and that the OJT operates within the requirements of Federal and state requirements, as well as within guidelines of its own policies and procedures?
☐ YES ☐ NO  
3.a.3.
  • The LWIA is capturing data on its OJT sufficient to chart progress toward its goals for the OJT and is sharing this information with key policy officials?
☐ YES ☐ NO  
3.a.4.
  • The LWIA has involved partner agencies to support the OJT as outlined in its plan for OJT?
☐ YES ☐ NO  
3.a.5.
  • The LWIA has procedures and an appropriate process for selecting employers when there is competition for limited funding available for OJT contracts?
☐ YES ☐ NO  
3.a.6.
  • LWIA OJT procedures clearly outline the OJT contract process, including the use of any prescribed forms, and that the process is being followed? 
☐ YES ☐ NO  
3.a.7.
  • OJT staff are following LWIA procedures setting requirements for use of the training outline, the process for determining the length of training, setting any limitations (on length of training, minimum wage rates, precluded occupations or industries, etc.), and how exceptions to these limitations can be granted?
☐ YES ☐ NO  
3.a.8.
  • Appropriate procedures for contract modifications are in place and being followed?
☐ YES ☐ NO  
3.a.9.
  • Procedures are in place and being followed concerning how any special training beyond the OJT paid for by the employer is invoiced and reimbursed?
☐ YES ☐ NO  
3.a.10.
  • The LWIA has and is following procedures to assure the trainee was not already been hired by the employer prior to the start date in the OJT contract?
☐ YES ☐ NO  
3.a.11.
  • Supportive services are provided to the trainee during OJT in keeping with LWIA policy and procedures?
☐ YES ☐ NO  
3.b. Do records reviewed indicate all case management and management information system requirements the LWIA and State are being met? ☐ YES ☐ NO  
3.c. Do LWIA reports to the State for OJT activities meet requirements for timeliness and accuracy? ☐ YES ☐ NO  
3.d. Do the files verify that OJT trainee time and attendance is certified by the employer prior to reimbursement to the employer? ☐ YES ☐ NO  
3.e. Do LWIA files verify that OJT monitoring is occurring as scheduled in its policies and procedures? ☐ YES ☐ NO  
3.f. Does LWIA monitoring check that employers establish record keeping and record retention systems to assure employer records adequately support OJT invoices? ☐ YES ☐ NO  
3.g. FINAL QUESTION:  Is the LWIA administering its OJT in compliance with Federal and State requirements, and with its own policies and procedures?

Summarize any issues:

☐ YES ☐ NO  
5. CONCLUSIONS    
5.a. Summarize any findings related to compliance here:    
5.b. Summarize any recommendations for improvement here:    
5.c. Summarize any technical assistance given on-site during the review here:    

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