Report 2015-508 All Recommendation 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

Recommendation #2 To: Employment Development Department

To ensure that the State maximizes federal funding opportunities related to workforce investment, EDD and the state board should formalize their collaborative grant-seeking procedures by December 31, 2015, to clearly define their respective roles and responsibilities in the grant-seeking process.

Annual Follow-Up Agency Response From May 2017

Effective January 7, 2017, EDD and the State Board have formalized their collaborative grant seeking procedures to define their respective roles and responsibilities in the grant seeking process. Typically, EDD will take the lead role in actively seeking federal grant opportunities. Prior to finalizing the decision to seek or forgo a grant opportunity, EDD seeks the State Board's input based on the grant analysis. The State Board may take the lead in situations where funding opportunities relate to the broader workforce development community.

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

EDD provided us a flowchart which describes the collaborative grant-seeking procedures, including the roles and responsibilities of both EDD and the state board.

1-Year Agency Response

As of June 30, 2016, the workload associated with the transitional activities required to successfully implement the Federal Workforce Innovation and Opportunity Act is well underway. As such, EDD and the State Board plan to collaborate to formalize the grant-seeking procedures. The procedures will clearly define their respective roles and responsibilities in the grant-seeking process.

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

6-Month Agency Response

This recommendation has not been fully implemented. Once the workload associated with implementing WIOA in the transition year (July 1, 2015 to June 30, 2016) is completed, EDD will continue to work with the State Board to 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 and the State Board are in development of grant-seeking internal processes and procedures, including coordinating efforts and roles and responsibilities for grant-seeking activities.

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

Recommendation #3 To: Workforce Investment Board, California

To ensure that the state board assesses the merits of pursing federal funding for workforce investment programs in California, it should establish procedures by December 31, 2015, that include, at a minimum, the following:
- The methods it will use to identify federal grant opportunities.
- The factors it will consider in its decisions to pursue or forgo applying for these grants.
- The process by which it will document its analyses of grants and its final decisions to either pursue or forgo grant opportunities.
- A method for ensuring that the process is consistently implemented.

Annual Follow-Up Agency Response From September 2017

The State Board continues to identify, review and analyze federal funding opportunities in close coordination with EDD, incorporating the recommendations of the Government Finance Officers Association that the State Auditor provided. The Administration Branch staff performs this work monthly on federal grant opportunities that fall outside the scope of EDD's federal grant seeking efforts. The State Board and EDD finalized the internal processes for how this new procedure is being used by the State Board and EDD. Documentation of these internal processes can be found in EDD's most recent response.

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

1-Year Agency Response

The State Board has established internal procedures for the identification, review and analysis of federal funding opportunities, incorporating the recommendations of the Government Finance Officers Association that the State Auditor provided. However, the State Board and EDD are continuing to finalize the internal processes for how this new procedure will be used by the State Board and EDD as part of our coordinated roles and responsibilities related to grant-seeking. The full implementation of the internal processes have been delayed due to WIOA implementation activities as noted in EDD's 1 year response.

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

6-Month Agency Response

The State Board has established internal procedures for the identification, review and analysis of federal funding opportunities, incorporating the recommendations of the Government Finance Officers Association that the State Auditor provided. However, the State Board and EDD are continuing to finalize the internal processes for how this new procedure will be used by the State Board and EDD as part of our coordinated roles and responsibilities related to grant-seeking. the full implementation of the internal processes have been delayed due to WIOA implementation activities as noted in EDD's 6-month response.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

60-Day Agency Response

The State Board has established internal procedures for the identification, review and analysis of federal funding opportunities, incorporating the recommendations of the Government Finance Officers Association that the State Auditor provided. However, the State Board and EDD are continuing to finalize the internal processes for how this new procedure will be used by the State Board and EDD as part of our coordinated roles and responsibilities related to grant-seeking.

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

Recommendation #4 To: Workforce Investment Board, California

To ensure that the State maximizes federal funding opportunities related to workforce investment, EDD and the state board should formalize their collaborative grant-seeking procedures by December 31, 2015, to clearly define their respective roles and responsibilities in the grant-seeking process.

Annual Follow-Up Agency Response From September 2017

This recommendation has been fully implemented as of December 2016. The State Board and EDD have agreed that EDD staff will actively search for Federal grant opportunities that will align with the California Strategic Workforce Development Plan (State Plan) and which support the delivery of employment and training services to California residents. In addition, the State Board may provide additional funding opportunities available through their broader Workforce Development Community by utilizing the procedure set forth in EDD's latest response to their recommendation number 1.

Based on the executive summary a determination will be made whether EDD or the State Board will be the lead for the application process. The lead will then reach out to required partners and stakeholders to begin the application process. The EDD Grants Unit and the State Board Administrative Branch will work in collaboration with each other to meet the application requirements and submit the application to the EDD Fiscal Program Division for submission on grants.gov when applicable.

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

1-Year Agency Response

The State Board and EDD continue to collaborate in the development of internal processes, procedures, and coordinated roles and responsibilities for grant-seeking activities. The development of the internal processes and roles and responsibilities continues to be delayed due to WIOA implementation activities. The State Board and EDD are collaborating to formalize the grant-seeking procedures. The procedures will clearly define their respective roles and responsibilities in the grant-seeking process. Both EDD and the State Board will continue to follow their independent grant seeking processes and share analysis of grant opportunities until the collaborative process is finalized.

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

6-Month Agency Response

The State Board and EDD continue to collaborate in the development of internal processes, procedures, and coordinated roles and responsibilities for grant-seeking activities. The development of the internal processes and roles and responsibilities has been delayed due to WIOA implementation activities and turnover of key staff in the area of grant seeking. On March 16, 2016 the State Board and EDD staff met to revise and merge the grant seeking activities of both organizations. both EDD and CWDB will continue to follow their independent grant seeking processes until the collaborative process is finalized.

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

60-Day Agency Response

The State Board and EDD are in development of internal processes, procedures, and coordinated roles and responsibilities for grant-seeking activities.

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

All Recommendations in 2015-508

Agency responses received are posted verbatim.