R1. Goal Achievement
Centers operated by contractors and federal agencies, and Outreach and Admissions/Career Transition Services (OA/CTS) contractors, must establish:
a. Procedures to develop and clearly communicate goals to staff and students
b. Procedures to hold staff responsible for achieving communicated goals
R2. Quality Assurance
Centers operated by contractors and federal agencies, and OA/CTS contractors, must:
a. Establish procedures and conduct periodic self-evaluations and audits to ensure integrity, accountability, and prevention of fraud and program abuse. The Quality Assurance Plans and Procedures shall be submitted annually to the Regional Office for approval, as outlined in Exhibit 5-2. Approval of the Quality Assurance Plan shall be based upon:
1. The extent to which the oversight, monitoring, and assessment plan will provide a reasonable assurance of contractor/agency compliance and quality.
2. The extent to which the contractor’s/agency’s data validation system ensures the accuracy and integrity of student outcomes and financial data.
3. The extent to which the contractor’s/agency’s quality assurance activities track and ensure that corrective action is taken to maintain outcomes and quality standards.
4. The degree to which the contractors/agencies document the results of inspections, tests, audits, and assessments.
b. Establish systems to ensure performance is accurately tracked and reported, and necessary corrective actions are taken to achieve the performance outcome goals and quality standards established by the National Director, Job Corps, and contained in Appendices 501a, 501b, 501c, and 501d.
c. Conduct comprehensive assessments of center or OA/CTS operations.
Job Corps Regional Offices shall perform unannounced assessments on a risk management-based schedule. Regional Office Center Assessments (ROCAs) will occur twice during the life of a contract, ideally during Year 2 and Year 4. ROCAs for Forest Service centers will occur every 2 years. Assessments for centers on a Performance Improvement Plan (PIP) will occur annually. Targeted assessments, which may also be unannounced, will focus on program areas that are deficient in the initial or full assessment, or identified as potential causes of concern based on a risk analysis.
Triggers that could initiate a targeted or full assessment:
1. Unfavorable results of performance, operational and/or financial audits
2. Issues with student safety, security and culture
3. Constituent complaints (includes e-mails, telephone calls, and hotline report)
4. Unsatisfactory center progress in response to a PIP
5. Category of performance that is significantly below standard
6. Failure to address initially cited Regional Office Center Assessment (ROCA) weaknesses
7. Significant Incident Reports (either a very serious single incident or a negative trend)
8. Sharp decline in Student Satisfaction Survey results
9. Significant facility issues
10. Significant findings and concerns on operator annual assessments
d. Conduct audits of approximately 10 percent (contracted On-board Strength [OBS] or average CTS caseload) of all student records associated with performance measurements during center and CTS program assessments, using targeted samples generated by the National Office of Job Corps.
e. Document the results of program assessments and audits, and provide a copy of the completed report to the National Office and the contractor or federal agency. If excessive reporting problems are present, the extent of misreporting shall be brought to the immediate attention of the Office of Job Corps.
f. Assess liquidated damages from contractor’s base/incentive fee for instances of misreporting data based on the following schedule:
Invalid HSD/HSE Credits
Invalid CTT Completion Credits
Artificially Extending Enrollment
and/or Invalid Leave Days
15% of the Student Year Cost (SYC) per day
The amount is calculated as (annual operating budget/planned SYs) X 15% X Number of Unexcused Days.
Invalid Placement Credit
g. Require the operator to post the liquidated damages to the fee line applicable in the ETA 2110 form. The region will request an Annual Advanced Procurement Plan/Financial Operating Plan (AAPP/FOP) change to document the assessment or damages and recover the funds through a contract modification. Misreporting data by agency-operated centers shall be reported to the Office of Job Corps and the respective federal agency for corrective action.
Notify the Office of Job Corps and the Job Corps Data Center (JCDC) to remove invalid (High School Diploma/High School Equivalency [HSD/HSE], career technical training (CTT) completion, and Placement) credits from the Outcome Management System(s) (OMS).
Note: Invalid credits will be removed from each measure that is affected regardless of the report card (OMS, Outreach and Admissions Outcome Measurement System [OAOMS], Placement Outcome Measurement System [POMS], CTT Report Card [CTTRC]) or contractor responsible for the error (OA, Center, or CTS). For example, where verification of a HSD/HSE has been invalidated, credit would be removed for the HSD/HSE Attainment measure. In this instance, if the HSD/HSE was the sole determinant of his/her graduate status, the student would also be removed from the pool for any placement-related measure(s) in the OMS, POMS, and CTTRC report cards. Similarly, a credited placement that has been found to have been misreported by a CTS provider would lead to the removal of the student from the placement pool of both the CTS and the center OMS report cards. Both scenarios hold true whether the center operator and the CTS provider are separate, or one and the same.
h. Contracting Officers must exercise discretion when assessing liquidated damages in cases where an error or omission occurred, or when the action was determined to be careless or was the result of an innocent mistake. This is particularly true if the data was improperly recorded but the student outcome was likely achieved. For example, a CTT completion, a HSD/HSE credit, or a placement credit that was incorrectly reported but there is verification that the student actually did earn the credit.
i. When a Contracting Officer becomes aware of apparent fraud, the matter should be thoroughly investigated. If the investigation leads the Contracting Officer to conclude there is a likelihood of fraud, it should be referred to the Regional Office of the Office of Inspector General (OIG) by filing an incident report.
In addition to filing the report, the Contracting Officer will inform the OIG of the actions intended to address the incident. The Contracting Officer will make it clear that he/she intend to take these actions, unless the OIG specifically instructs the Contracting Officer not to do so. The Contracting Officer will then proceed with contract enforcement, unless otherwise directed.
R3. Standard Operating Procedures and Plans
Center contractors, agencies, and OA/CTS contractors must:
a. Establish standard operating procedures (SOPs), as shown in Exhibit 5-1 (Standard Operating Procedures), and submit them to the Regional Office for approval within 90 days of contract award. Updates and revisions shall be submitted as changes occur.
b. For agency-operated centers, provide up-to-date SOPs, as shown in Exhibit 5-1, with annual plans and amendments to SOPs submitted to the Department of Labor (DOL) Regional Office for approval by June 1 for the upcoming program year.
c. Career Development Services System Plan
Each Job Corps Center and each OA/CTS contractor must:
1. Develop a Career Development Services System (CDSS) Plan. The Plan must include:
(a) An overview of the contractor’s/federal agency’s role in each phase of CDSS, as appropriate for each contractor/agency.
(b) A description of how services will be delivered and coordinated with other partners for Outreach/Admissions, Career Preparation, Career Development, and Career Transition Periods.
(c) The requirements shown in PRH Chapters 1-4, as applicable.
2. CDSS plans shall be submitted to the Regional Office for approval within 90 days of contract award. Agency centers shall submit the plan for approval when required by the DOL Regional Office. Approval shall be based on a determination that all required parts of the plan are in place, and that the plan is consistent with the overall Regional CDSS Plan.
3. CDSS plans shall be kept current. Revisions shall be submitted to the Regional Office for approval prior to implementation.
Center operators, federal agencies, and OA/CTS contractors shall submit reports in accordance with Exhibit 5-2 (Plan and Report Submission Requirements).
R5. Records and Reports Maintenance
Center operators, agencies, and OA/CTS contractors must maintain records and reports for three years. Records of disclosures of protected health information shall be kept for six years. Exceptions to this retention period shall be communicated by the National Office of Job Corps on a case-by-case basis.