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THE WORKFORCE INVESTMENT ACT
STATE APPROVED WIA IMPLEMENTATION PLAN

Plan Overview |Executive Summary |Plan Development |Vision and Goals
Labor Market
| One Stop Center | Performance Measurement | Adult Programs
Local WIA / State Coordination | Youth | Administration

IX. Administrative and Operational Controls

IX. A. Identify the entity responsible for the disbursement of grant funds.

Grant Recipient:
Pima County Board of Supervisors
Sharon Bronson, Chair
130 W. Congress Tucson, Az. 85701

Administrative Contact:
Hank Atha
Pima County Community Services
32 N. Stone-16th Floor Tucson, Az. 85701

Fiscal Contact:
Ron Meck
Pima County Community Services
32 N. Stone-16th floor Tucson, Az. 85701

IX B. Describe the procurement and competitive process to be used to award grants and contracts in the local area for activities carried out under this subtitle.

Pima County's Workforce Investment Board shall utilize both a Request for Proposal (RFP) process and a Request for Qualified Vendor (RFQ) process. Requests for Proposals shall be for providers of comprehensive services for youth, adults, and/or dislocated workers, including services to be provided by community based organizations in accordance with WIA Sec 134 (d)(4)(G). Requests for Qualified Vendors shall be used to solicit fee for service activities. Such activities may include but not be limited to vocational training, behavioral counseling, transportation services, development of curriculum, workshop presentation, training for staff, and general technical assistance.

Request for Proposals

The Workforce Investment Board shall assess community needs, allocate funds to meet those needs, establish general parameters for services, and designate a Committee of the Board to issue a Request for Proposals. Parameters shall include consideration of reasonable cost, past experience, quality of service, the likelihood of meeting performance goals, past documented performance, and fiscal integrity.

The RFP shall be announced though legal notices in the newspapers, and letters to potential service providers that have asked to be on the WIA RFP list. Potential providers may place themselves on the list by writing a letter to:

WIA Procurement Process
32 N. Stone 16th Floor
Tucson, Az. 86701

The RFP shall include background information, including Workforce Board expectations, instructions, relevant forms, required certifications, and evaluation criteria. RFPs shall be submitted to a specified place by a specified time and date. Late submissions will not be accepted.

The designated Committee shall meet to review proposals. The Committee reserves the right to request oral presentations from proposers, and reserves the right to request written clarification by proposers. The Committee shall recommend Provider(s) and amounts to be awarded to the full Board. The Workforce Investment Board shall then review the Committee's recommendations and vote on service providers and allocations.

The Board shall establish an appeals committee and proposers shall be given a date, time and place to submit written appeals. Appeals shall address a perceived flaw in the competitive process.

If any appeals are submitted, the Appeals Committee shall meet to review them. The Appeals Committee shall make its recommendations to the Workforce Investment Board, which shall make final allocations.

Requests for Qualified Vendors

The Workforce Investment Board shall assess community needs, allocate funds to meet those needs, establish general parameters for services, and designate a Committee of the Board to issue a Request for Qualified Vendors. Parameters shall include consideration of reasonable cost, past experience, quality of service, the likelihood of meeting performance goals, past documented performance, and fiscal integrity.

The RFQ shall be announced though legal notices in the newspapers, and letters to potential service providers that have asked to be on the WIA RFQ list.

The RFQ shall include background information, including Workforce Board expectations, instructions, relevant forms, required certifications, and evaluation criteria. RFQs shall be submitted to a specified place but may be submitted at any time. The designated Committee shall meet to review proposals. The Committee reserves the right to request oral presentations from proposers, and reserves the right to request written clarification by proposers. The Committee shall recommend Provider(s) and fee for service unit costs to the full Board. The Workforce Investment Board shall then review the Committee's recommendations and vote on them

IX C. Provide a description of your Fiscal Agent Procedures.

IX C 1. Fiscal Control

Pima County Community Services (CSD) is a department within Pima County government. We are subject to all the fiscal procedures, forms, and regulations of all Pima County departments.

All capital purchases are subject to Pima County Purchasing procedures, which are based on State Statutes. The purchasing rules and procedures are contained in the "Administrative Procedures Manual" of Pima County written by the County Administrator's Office. A copy of the manual is on file with the Fiscal Section at 32 N. Stone, 16th Floor, 740-5205.

IX C 2. Accounting

Claims require official Pima County forms, authorized signatures, appropriate documentation, account codes, and cost centers before being submitted to Pima County Finance.

IX C 3. Payroll

Payroll is processed by Pima County Finance Department biweekly. Time cards with signatures by the supervisor and employee are used to complete payroll forms provided by Finance. All pay rates, job titles, and job descriptions are established and maintained by the Pima County Human Resources Department. All payroll documents must be completed according to the Finance Payroll Manual. Payroll hours are input by Department staff, but all calculations and processing are done by Pima County General Services Department.

IX C 4 Audit

The County is subject to the Single Audit Act and is audited by the Auditor General of Arizona annually. The Community Services Department is included in that audit.

IX C 5 Debt Collection Misspent funds or unliquidated debts will be collected by CSD from subrecipients by written corrective action that will specify amount of payment(s) and payment timeliness. Debt collection will be attempted by CSD and the County when it is appropriate and feasible. Unresolved debts will be turned over to the Finance Department collection division, which is responsible for collecting outstanding debts. The County Attorney, Civil Division, will assist in this effort.

IX C 6 Cost Allocation

Service costs are allocated back to departments based on the unit of activity of the servicing department. Heating and cooling are allocated based on square footage, personnel costs are allocated by personnel transaction requests, etc.

IX C 7 Budget Development

Budgeting for WIA is part of the County's budget process. This occurs every spring. The County shall review WIA cost limitations, rules and procedures, as well as recommendations and allocations of the Workforce Investment Board in developing the budget. The county will modify the budget through the appropriate administration revision process. Any allocation increases or decreases greater than l5% will require a Plan revision.

IX C 8 Recordkeeping/Retention

CSD will keep accounting records which meet the requirements of the State and County, generally accepted accounting principles, and pertinent Federal law and regulations. Such records shall record all expenditures which are used to support invoices and requests for payment. CSD will maintain records which identify the source and application of any funds used to support activities provided under the Agreement with the State. Such records shall meet generally accepted accounting principles.

IX D Provide a description of the procedures to be used to resolve all Grievance and Appeals.

Each participant will be given a copy of the grievance policy. He/she shall sign a receipt for this policy and the receipt shall be placed in the client's file.

Any non-criminal complaints alleging a violation of WIA, its regulations, grant or other agreement under the Act filed by a participant, contractor, employer or other party will be handled by the CSD-WIA Administration.

Upon receipt of a complaint, an investigation will take place and informal resolution will be attempted where practicable. If informal resolution is not achieved within thirty (30) days of the filing of the complaint, a hearing will be scheduled with the WIA Manager serving as hearing officer. All parties of interest shall receive a written notice of the hearing which will include the date, time, and place of the hearing. There will be an opportunity for all affected parties to present evidence at the hearing and a written decision will be rendered within sixty (60) days of the filing of the complaint.

The final decision will be accompanied by instructions as to when, how, and where a review by the Governor of this decision may be requested.

All complaints that relate to terms and conditions of employment by participants who are employees (i.e., OJT participants) will be handled under the existing procedures of the employers for whom they work. Employers will be required to inform their OJT employees of the procedures which they are to follow. Within ten (10) days of receipt of the final decision of their employer, OJT participants may request, in writing, that the Pima County CSD Administration review this decision.

Upon receipt of such a request, the case will be reviewed and a decision rendered within thirty (30) days. If necessary, the request will be referred to the Governor for review.

Complaints of discrimination on the ground of handicap, race, color, national origin, age, sex, religion, political affiliation or belief, shall be sent directly to:

Directorate of Civil Rights
U. S. Department of Labor
200 Constitution Avenue, N.W.
Washington, D.C. 20210

With the exception of handicap discrimination, complaints will be accepted for a period of one year from the date of the alleged violation. In accordance with WIA and as per 29 CFR, Part 32, referred to therein, handicap complaints will be accepted for a period of 180 days from the date of the alleged violation.

Each subcontractor maintains internal procedures for addressing complaints originating at the subcontractor level. All subcontractor internal grievance procedures should be exhausted before the CSD steps in to handle complaint.

IX E Describe the methods to be used in monitoring, including but not limited to program and fiscal compliance.

Contracts with subrecipients are monitored internally and by Finance to insure no excess or duplicate payments are made. All deposits are made with the Pima County Treasurer within 24 hours of receipt. The Finance department produces the official accounting reports each month. The official reports are augmented by internal monthly reports by CSD fiscal staff. Second level of program review will be undertaken by the fiscal section CSD staff will monitor fiscal matters on a monthly basis to assure accurate reconciliation between advances, invoice billing, support documentation and contractual agreements. Both the accounting section and the designated program staff member verify the accuracy of the fiscal reporting and billing systems. This approach relies heavily on MIS participant records for making accurate certifications.

CSD staff will monitor on-site subcontractors on an annual basis for overall program activities and financial tests. CSD has set up a system composed of a Program Specialist who is primarily responsible for all subcontractor monitoring. She conducts monthly desk reviews on each subcontractor and official on site reviews on an annual basis. The desk review focuses on systems analysis and policies and procedures as required by County directives and contract documents.

IX F Provide a brief statement on the Affirmative Action commitments. Describe the method to monitor and evaluate AA. Also include as an attachment a copy of the document which states your policies and procedures for ensuring program and site access to persons with disabilities in compliance with the Americans with Disabilities Act.

See Attachment E: Affirmative Action and ADA

Pima County SDA is subject to Pima County's Equal Opportunity and Affirmative Action Policy Number D-21.1. In addition, contractors are subject to WIA provisions and must sign the Pima County Employment & Training Administration Standard Provisions.

The Americans With Disabilities Act (ADA) is intended to eliminate discrimination against people with disabilities. Included in the law are provisions regarding employment, communications, governmental services, public transportation and accommodations provided by public entities.

Pima County complies with the provisions of the American With Disabilities Act of 1990. In accordance with the Act, the SDA requires contractors to insure program and site access to individuals with disabilities including applicable auxiliary aids, auxiliary services, access phone numbers, and site selection. Contractors are monitored at least once yearly at which time there is a site inspection and an EEO Review Questionnaire which is completed with regard to ADA compliance.

IX G Provide a brief statement on Equal Opportunity commitments. Describe the method to monitor and evaluate EO.

Pima County SDA complies with Section 167 of PL 97-300 (as amended by PL 102-367), Title VI of the Civil Rights Act of 1964 (as amended), Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975 (as amended), the Americans with Disabilities Act of 1990, all requirements imposed by or pursuant to the implementing regulations in 29 CFR Parts 31, 32, and 24. This assurance is incorporated in all grants, contracts, and cooperative agreements made by CSD.

CSD responds on request to EEO auxillary aid(s) and accessible phone numbers. There is an agreement with Community Outreach Program For The Deaf to provide signing services and there is the capability to provide electronic aid. The Pima County staff will conduct EEO and affirmative action monitoring. CSD will conduct yearly reviews in compliance with WIA Laws and Regulations for existing providers and initial reviews for new providers within six months of award of contracts.

IX H Describe the liability policy/procedures to be used by the fiscal agent and how audit exceptions will be satisfied.

CSD is an arm of a unit of local government and as such has procedures for debt collection, audit resolution and liability coverage to address the general issue of liability. The specific procedures to be utilized for audit resolutions will be in compliance with Federal Register rules and regulations and State directives.

IX I If the fiscal agent has an authorized Indirect Cost Rate, state what this rate is and attach a copy of the authorizing document from the cognizant agency.

Health and Human Services is the cognizant agency. Pima County does not anticipate charging an indirect rate to WIA

IX J indicate if your LWIB intends to request a transfer of funds from the Adult to the Dislocated worker program or vice versa.

The maximum amount allowed to be transferred is 20%. The Pima County WIB reserves the right to transfer funds across titles as necessary, in coordination with the State of Arizona WIA Administration.

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This page last updated: 2/22/05