ACTION BULLETINS (PY 2005)
AB - 59 Exit Review of Case Files
AB - #59
Effective Date: Retroactive to July 1, 2005
ACTION BULLETIN
Exit Review of Case Files
TO: One-Stop Career Centers Site Managers
DATE: October 25, 2005
SUBJECT: Exit Review of Case Files
PURPOSE OF BULLETIN:
The purpose of this bulletin is to outline the procedure for an exit review of 100% of the participant case files at time of exit determination from a WIA funded service through the One Stop Center system.
BACKGROUND:
The Workforce Investment Act (WIA) program is designed as a tiered service level approach to service. There are four (4) service levels: self-directed, staff-assisted, intensive and training. WIA eligibility determination is required at the point the job seeker needs staff-assisted services to obtain and/or retain employment. As the job seeker moves through the service levels additional requirements must be met to show that the job seeker is appropriate for the next level of service to obtain and/or retain employment. The Certification/Information Processing Unit (C/IPU) of the Alameda County Workforce Investment Board (ACWIB) is responsible for ensuring job seeker eligibility at the point of entry into staff-assisted services.
The responsibility for ensuring the requirements are met at the point of entry into the Intensive and/or Training service levels is documented in the participant case files maintained by the One Stop Career Center site. ACWIB staff has developed a procedure for the One Stop Career Center to implement that ensures 100% of the participant case files are reviewed for completeness upon determination of exit. The procedure includes a checklist, completed by the case manager, and signed by the site manager to verify all necessary documentation is in the case file to substantiate movement between each service level.
Several concerns have necessitated the new procedure and checklist. First, was the visit from the Office of Inspection General in the month of August. Their findings, though not requiring corrective action at this time, revealed several discrepancies in case file documentation, specifically in the lack of case notes to document an “active service”, at least once every 90 days; in the lack of documentation of training attendance when the job seeker receives WIA funded training; and incomplete or blank Individual Employment Plans. Though the findings did not find discrepancies for all of the One Stop Career Centers, the lack of documentation raised monitoring concerns for ACWIB, since ACWIB staff is responsible to ensure compliance with requirements for the four tiered service level design.
Secondly, the documentation requirements are not new. They have always been mandatory and are outlined in other tools currently in use:
· The Case File Review Worksheet used during ACWIB monitoring visits,
· The Eligibility Technical Assistance Guide (TAG) that outlines the requirements for movement through the tiered service levels, and
· The Counselor’s ITA/OJT Procedures Handbook developed by OPIC.
Since the documentation requirements were outlined in several tools, Staff determined there was need for a centralized quality control tool for 100% of the participant case files. A primary factor in this decision is that ACWIB monitors only a random sampling of participant case files annually in order to comply with our role as the WIA administrative arm that does not address 100% of the participant case files.
This brings up a third concern. Many of the participant case files, not monitored by ACWIB, will be chosen for audit by other entities required to monitor WIA enrollments, such as OIG, the State Workforce Investment Division (WID), Department of Labor (DOL), and independent auditors monitoring the County. Since WIA is a well-monitored program, it is staff’s contention that the One Stop Career Centers should monitor 100% of their own case files.
PROCEDURE:
The procedure requires case managers and site managers to review, at time of exit determination, 100% of the participant case files to ensure that documentation for participation in each of the service levels is fully documented, and then complete and sign the Checklist. The time of exit determination was chosen as the checkpoint because this is usually the last opportunity for direct contact with the customer if additional documentation needs to be obtained.
ACWIB staff will be adding evidence of the completion of the Checklist for 100% of all exited participants to the Case File Review Form used in our annual monitoring visit.
An additional MIS form, “The Intensive Service to Training Service Determination Form” is required to be submitted to the C/IPU along with all enrollment forms into a training activity. A copy is retained in the participant case file.
The Checklist, the directions for completing the checklist, and “The Intensive Service to Training Service Determination Form” follow.
Information & Inquiries
Please contact Linda Slater, MIS Manager, at (510) 259-3802 or lslater@acgov.org with any questions regarding the information bulletin.
EXIT REVIEW OF CASE FILES
Job Seeker Name ________________________________ Last Four SSN ___________
REQUIRED FOR ALL ENROLLMENTS
There is a case note documenting an “active” service on the date of enrollment.
There is a case note documenting an “active” service, at least 1 every 90 days.
There is a case note documenting an “active” service on the date of exit .
Customer is employed on date of exit? Possibility that wages will not appear in base wage? A tickler is set for 1st, 2nd, and 3rd quarter(s) after exit to follow-up with supplemental data.
Customer contact information is current. Customer reminded about follow-up.
REQUIRED FOR INTENSIVE SERVICE ENROLLMENTS
There is a comprehensive Assessment.
There is a completed and signed Individual Employment Plan (IEP).
REQUIRED FOR TRAINING ENROLLMENTS
There are training attendance and progress reports.
There is a copy of the credential/certificate. Reported to MIS?
Case Manager Signature_________________________________ Date _____________
Site Manager Signature __________________________________ Date _____________
DIRECTIONS FOR COMPLETING THE CHECKLIST
Indicate Job Seeker Name and last four digits of social security number. The completed checklist is kept in the case file for monitoring review by ACWIB staff and other auditors.
REQUIRED FOR ALL ENROLLMENTS
The first three check boxes refer to maintaining viable case notes. In order to substantiate that the customer is actively participating in WIA funded services, in each service level, there must be case note documentation of an “active” service:
1. On the Date of Enrollment,
2. At least one (1) every ninety (90) days, at a minimum, and
3. On the Date of Exit
Alameda County WIB Action Bulletin #54, July 1, 2005, outlines, from the Employment and Training Guidance Letter (TEGL) 28-04 issued in April 2005, what is NOT considered an “active” service:
· A determination of eligibility to participate in the program,
· Self-directed job search that does not result in a referral to a job,
· Services and activities specifically provided as follow-up services or regular contact with the participant or employer for purposes of obtaining information regarding his/her employment status, educational progress, need for additional services, or income support payments.
All other services are considered “active”. The case file must have a case note documenting an active service was provided: On the date of enrollment, on a regular basis, at a minimum, once every 90 days, and on the date of exit.
The TEGL also defines the when a customer must be exited:
· When participant does not receive a service funded by the program operator or funded by a partner program for 90 consecutive calendar days and is not scheduled for future services.
At that point, you must exit the customer retroactively back to the last documented date of “active” service.
This requirement necessitates that the case manager document with case notes, regular attempts to stay in contact with the customer, setting ticklers and follow-up reminders. It also means that the program must take “negative” exits when unable to locate customers who have not received any “active” service for 90 or more days.
The last two check boxes, in this area, relate to employment and follow-up.
When a customer obtains employment, the case manager should evaluate the possibility that the wages will not show up in the Base Wage Record (BWF) in the 1st quarter after exit. This is likely to happen if the customer is self-employed, a contract employee, in the military, taking a job out-of-state, employed by the postal service, or other federal agency.
The case manager should document with a case note that employment was obtained and a tickler is set for 1st, 2nd, and 3rd quarter(s) after exit to follow-up with supplemental data.
In order to ensure successful follow-up, the case manager should also make sure that the customer’s contact information is current, and that the customer is reminded they will be called to follow-up on their progress after exit.
REQUIRED FOR INTENSIVE SERVICE ENROLLMENTS
Enrollment into the Intensive Service level means that the customer requires one-on-one assistance to obtain and/or retain employment.
When the case manager submits the MIS enrollment form enrolling the customer into one or more Intensive Service activities, the “Staff Assisted to Intensive Service Determination Form” must accompany the enrollment.
There must be a comprehensive Assessment of skills, aptitudes, interests and needs. The assessment should include documentation of:
· Prior work history, including lapses in employment,
· Education,
· Financial support, including salary expectations,
· Familial support, including barriers like child-care, health and transportation, and
· Occupational objectives.
There must be an Individual Employment Plan (IEP), outlining the planned services required to meet the employment, educational, financial, familial, and occupational objectives determined through the assessment.
The IEP outlines the step-by-step process, including estimated completion dates for each step, to achieve planned goals. Both the customer and the case manager sign the IEP.
The IEP should be updated, as needed, to address new planned goals, like delivery of support services, a change in objectives, or movement into the training service level.
REQUIRED FOR TRAINING ENROLLMENTS
Enrollment into the Training Service level means that the customer requires occupational skills/upgrade/on-the-job training to obtain and/or retain employment.
When the case manager submits the MIS enrollment form enrolling the customer into a Training Service activity, the “Intensive Service to Training Service Determination Form” must accompany the enrollment.
In order for a customer to enter an occupational skills training provider program listed on the Eligible Training Provider List (ETPL) the customer must complete the following steps:
· Have good attendance at the Intensive Service Level
· Have explored all other funding options
· Have completed an appraisal of several schools offering the occupational training of interest
· Have completed labor market research to ensure the occupational training of interest is in a growth industry within the greater Bay Area.
Attainment of each step is documented in a case note in the case file. These case notes substantiate that the customer did follow the proper procedure for researching training providers.
On-the-Job (OJT) training skills enrollment will not necessitate the above steps because the employer defines the steps for enrollment into OJT.
Upon completion of the required steps a Career Counselor Worksheet: Training Account Purchase Order and ETPL printout are submitted to the Oakland Private Industry Council (OPIC) for processing. A copy is retained in the case file.
Attendance and progress reports are required to substantiate that the customer is successfully progressing in the training program funded with WIA funds.
Upon successful completion of the training program, a signed credential/certificate from the training provider is in the case file. Check to ensure that the credential/certificate attainment is correctly reported on the MIS exit form.
When the customer does NOT successfully complete the training program, a copy of the Career Counselor Worksheet: Purchase Order Cancellation/Refund form is in the case file.
SIGNATURES
The checklist is completed by the site manager, or designee, then signed by both the case manager and site manager prior to submittal of the MIS exit form.
Intensive Service to Training Service
Determination Form
Customer Name: ___________________________________ SSN: _______________
q Individual Employment Plan (IEP) complete and signed/dated by the Customer
Based on an objective assessment of skills, aptitudes, interests, preferences and customer choice.
Customer determined to be in need of training and has the skills and qualifications to successfully participate.
Training in a demand occupation with career growth.
Unable to obtain or retain employment that leads to self-sufficiency through Intensive Services
q Obsolete/Inadequate Job Skills
q Insufficient Education for Job sought
q Lack of Public Job Orders
q Lack of Transferable Skills
q Lack of Work Readiness Skills
q Wage Variables
q Economic Conditions in the Local Workforce Investment Area
q Industry Contraction/Restructure
Good Attendance in at least one (1) Intensive Service
q Case Management for Participants
q Comprehensive Assessment
q Development of Individual Employment Plan
q Individual Counseling and Career Planning
q Short Term Prevocational Services
q Other Intensive Services
q Non-WIA funded Intensive services provided by partner agencies
Accomplished the following tasks prior to Training Enrollment
q Applied for other Financial Aid as appropriate, including Pell
q Completed a performance appraisal of several schools
q Conducted an informational interview, job shadowing, labor market research, or incumbent interview in field of interest
q Visited school, toured the facility, and talked to current students
q Reviewed family finances with job seeker to ensure family has assessed self-sufficiency while in training
q Other ____________________________________
Staff Signature:______________________________________ Date:______________
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