Report 2015-508 Recommendation 1 Responses

Report 2015-508: Follow-Up—Federal Workforce Investment Grants: The Employment Development Department Established Procedures for Seeking Discretionary Grants, but Needs to Strengthen Them (Release Date: September 2015)

Recommendation #1 To: Employment Development Department

To ensure that its grant-seeking process is effective in considering grant opportunities related to workforce investment, EDD should update its grant identification and analysis procedures by December 31, 2015, to include the following:
- Identification of the appropriate level of management or staff to analyze and document the factors considered in pursuing or forgoing grant opportunities.
- Documentation of grant analyses, including factors considered in pursuing or forgoing grant opportunities.
- Documentation of decisions related to pursuing or forgoing grants.
- A method for ensuring that the process is consistently implemented.
- Training of appropriate management or staff about EDD's grant-seeking process.

Annual Follow-Up Agency Response From May 2017

As stated in the 60-day response, which was uploaded on November 9, 2015, EDD reported that it reestablished the Grants and Special Initiatives Unit to analyze and document the factors considered in pursuing or forgoing grant opportunities.

Regarding documentation of grant analyses, effective February 2017, EDD completed the modification of the procedures for this process, including factors considered in pursuing or forgoing grant opportunities (examples can be provided upon request).

Effective February 2017, EDD implemented a tracking system to identify all potential grant opportunities, which includes the requirements set forth for each grant. The EDD also maintains documentation, which supports the decisions related to pursuing or forgoing grants.

In an effort to ensure that the process is consistently implemented, EDD provides training to the Grants and Special Initiatives Unit staff and management in properly documenting all aspects of the grant-seeking process. Additionally, the grant manager reviews all decisions and related documentation to ensure that the process is being followed.

Based on the above efforts, EDD considers all requirements of Recommendation 1 fully implemented.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

EDD provided its Organizational Chart for the Grants and Special Initiatives Unit, and a copy of its Grant Opportunities Procedures, its Grants Research Tracking Sheet, and its grant seeking training outline.

1-Year Agency Response

As stated in the six-month response, EDD has fulfilled one part of the recommendation. The EDD re-established the Workforce Services Branch Grants Unit to analyze and document the factors considered in pursuing or forgoing grant opportunities.

As of June 30, 2016, the workload associated with the transitional activities required to successfully implement the Federal Workforce Innovation and Opportunity Act are well underway. As such, EDD is now able to redirect its efforts to develop and implement: the documentation of grant analyses and decisions related to pursuing or forgoing grants, a method for ensuring that the process is consistently implemented, and the training of appropriate management and staff regarding EDD's grant-seeking process.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

6-Month Agency Response

This recommendation has not been fully implemented. As stated in the 60-day response, EDD has fulfilled one part of the recommendation. The EDD re-established the Workforce Services Branch Grants Unit to analyze and document the factors considered in pursuing or forgoing grant opportunities.

The EDD has made the workload associated with the implementation of the Workforce Innovation and Opportunity Act (WIOA) one of its top priorities. Since July 1, 2015, EDD has been doing its part to implement WIOA in California in its dual role of WIOA Title I Administrator and WIOA Title III Service Provider. While full implementation of this new federal legislation (which brings nearly $500 million in resources to our State) will take several years, this first transition year (July 1, 2015 to June 30, 2016) is especially critical to ensuring that California complies with all of the new WIOA-related requirements. The result is that the grant-seeking procedural updates referenced in the report are not expected to be updated any earlier than June 30, 2016. In the interim, EDD Workforce Services Branch staff continue to carry out its grant-seeking work using the existing business processes without any reduction in efficiency or quality.

Once the workload associated with implementing WIOA in the transition year (July 1, 2015 to June 30, 2016) is completed, then EDD will develop grant-seeking internal processes and procedures, including coordinating efforts and roles and responsibilities for grant-seeking activities.

California State Auditor's Assessment of 6-Month Status: No Action Taken

60-Day Agency Response

This recommendation has not been fully implemented. The EDD will evaluate its grant identification and analysis procedures to address the following:

- The responsibility of analysis and documentation of factors considered in pursuing grant opportunities has been assigned to the Staff Services Manager I and support staff in the newly re-established EDD/Workforce Services Branch Grants Unit. It has been determined that this assignment level is appropriate for initial analysis. As EDD indicated in the draft report, the leadership and management remain dynamic and responsive; therefore, guidance and procedures will change over time to reflect how grant opportunities are managed.

- The EDD is modifying the grant analysis process, including the executive summary component. In addition, EDD will evaluate the elements required to document grant analyses (e.g., the basis for pursuing or forgoing grants). Other decision-related elements will also be evaluated and incorporated to ensure documentation is returned to the Grants Unit for recordation in the tracking tool.

- As noted in the second item, documentation of decisions related to pursuing or forgoing grants is being addressed. The EDD is encouraged, as stated in the fourth paragraph of our response letter dated September 22, 2015, that the CSA's audit found "the decisions that were made by EDD all had merit (and) the decisions made by program experts on whether or not to seek grant opportunities were appropriate."

- The EDD is confident that the method described in the second item will enhance and support the procedures and ensure the process is consistently implemented.

- The EDD's Workforce Services Branch will provide training to appropriate management and staff.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

All Recommendations in 2015-508

Agency responses received are posted verbatim.