To fulfill its on-going, federally mandated oversight responsibilities CRC conducts regular desk and on-site monitoring reviews throughout the program year. We seek to conduct reviews sufficiently comprehensive and thorough to identify significant compliance violations and address possible areas of concern while at the same time providing guidance to program administrators and assisting with objective and quality outcome achievement.
Each year CRC develops a preliminary on-site monitoring review schedule and disseminates it to appropriate state and local entities. CRC strives to maintain schedule flexibility to accommodate local operations and is open to schedule changes pursuant to sufficient notification. Confirmation notices stating the entrance conference date are provided once firm review dates are determined. Monitoring review results are documented and compiled in a formal report and disseminated to the appropriate state and local entities for response and corrective action as warranted.
This page summarizes CRC's overall review methodology and specific process for conducting reviews. The following review procedural topics are discussed:
· Preliminary Contact/Meetings
· Entrance Conference
· Review Activities
· Exit Conference
· Report Format and Structure
· Corrective Action
CRC initiates review activities through preliminary contact with appropriate local administrators to briefly summarize the upcoming review and discuss possible review dates. If necessary, CRC may schedule a preliminary meeting to discuss the scope of the review, address areas of initial concern, and/or request materials for desk review prior to arriving on-site.
CRC conducts a formal entrance conference upon arriving on-site to discuss the upcoming review with administrators and staff. Entrance Conferences are generally brief and consist of CRC staff involved in conducting the review and designaged Local Area administrative staff. The Entrance Conference's primary objectives are to:
· Introduce CRC designated personnel to participating local staff;
· Discuss the review's purpose, goals, objectives, and timeline;
· Outline and answer any questions relating to the review's scope;
· Request necessary physical accommodations and designate a local contact person for relevant questions arising during the review;
· Discuss initial issues or concerns based upon prior reviews, a preliminary desk review, or alternative sources of information.
CRC's review activities, physical accommodations, personnel access requirements, and completion timeline vary depending upon the type of review. For instance, Adult/Dislocated Worker Service Provision reviews require both participant and case manager interview coordination, whereas data validation merely requires access to pre-selected participant files and a quiet workspace for file analysis. Financial/Administrative and Equal Employment Opportunity reviews require access to a substantial number of administrative files, policies, and procedures in addition to significant dialogue and interaction with administrative personnel.
Exit Conferences are scheduled subsequent to review activities and conducted after draft report completion. Exit conferences may be conducted in person or by telephone depending upon the significance of resulting review findings and/or CRC/local administrative staff availability. The Exit Conference's primary objectives are to:
· Summarize CRC review activities;
· Provide an overview of the draft report;
· Discuss general observations regarding performance relative to reviewed activities;
· Highlight recommendations for significant compliance violations;
· Recommend corrective action (when necessary);
· Answer administrative staff questions related to CRC observations and/or recommendations.
Report Format and Structure
CRC's report format and structure varies slightly depending on the review, however our uniform goals applicable to every report are to:
· Clearly articulate evaluative standards relative to each review;
· Thoroughly discuss observations and conclusions noted during the course of the review;
· Detail review procedures used to arrive at conclusions;
· Note areas of substantial compliance and recognize program accomplishments;
· Highlight compliance violations and/or programmatic areas needing improvement;
· Recommend corrective action when necessary and appropriate.
Reports begin with an "Executive Summary" section providing a quick overview of the report's observations and recommendations. The "Background" and "Scope of review" sections follow. These sections provide general context for the review and discuss program areas subject to evaluation. The "Review Section" contains the bulk of the report and additionally includes summaries of both the "Entrance" and "Exit" conferences. The "Review Section" is divided into segments organized according to areas of review, and each review area contains a summary of the relevant standard(s) evaluated against and utilized to arrive at our "Observations" and "Recommendations" sections, respectively. The "Observations" section discusses our review activities and conclusions arrived at pursuant to those activities. Finally, the "Recommendations" section lists action necessary to correct a noted program deficiency or remedy an explicit compliance violation.
The Corrective Action Board (CAB) reviews recommendations requiring corrective action and notifies the Deputy Secretary, Secretary, and/or Governor when corrective action is necessary.
When warranted, the Corrective Action Board will request a Corrective Action Plan from the entity being reviewed. Upon the Corrective Action Plan's approval the CAB chair will determine if the designated entity will be required to submit written progress reports. When required, each progress report shall describe actions taken, benchmark attainment/nonattainment, and any necessary plan revisions.
When appropriate, follow-up reviews may be conducted to ascertain if the corrective action plan was implemented and provide technical assistance as needed. In the event of significant compliance violations or a Corrective Action Plan's implementation failure the CAB may recommend possible sanctions to the Deputy Secretary, Secretary, and/or Governor. The CAB chair will notify all appropriate parties of any imposed sanctions and rights to appeal.