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 5.1 PROGRAM MANAGEMENT

 
 

 Purpose

 

P1. To establish and maintain systems that support the admission, career preparation, career development, and career transition of students.

P2. To monitor and track operations and outcomes to ensure program accountability, integrity, performance, and quality.​​

P3. To establish processes and assign responsibilities for handling media inquiries, and situations and circumstances when it is reasonable to anticipate media interest or participation.

 

 Requirements

 

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:

Description

Liquidated Damages

Invalid HSD/HSE Credits

$200 each

Invalid CTT Completion Credits

$500 each

Artificially Extending Enrollment

and/or Invalid Leave Days

15% of the budgeted cost per day, per student

The cost per day, per student is calculated as follows: (approved center operations budget that is in place for the contract year in which the misreporting occurs) / (duration of contract year in days) / (contracted student slots for the contract year)

Invalid Placement Credit

$750 each


 

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.

R4. Media Inquiries

Responsibilities of federal contractors and others operating Job Corps centers, as well as Outreach and Admission, and Career Transition Services contractors:

a. Notify the Job Corps Regional Office (RO) responsible for the region in which the center is located of all media inquiries, and provide a copy of each inquiry if it was submitted in writing.  The notice must be provided as early as practicable and should include the date, time, location, and point of contact for the request.
 
b. Coordinate with the RO to receive guidance on responding to incoming media inquiries before issuing a response.

c. Maintain the confidentiality of student information.  Personally Identifiable Information (PII) and any other information capable of identifying a student should not be released without the student’s written consent.  If the student is a minor, the written consent of the student’s parent or guardian is required before releasing information to the media or otherwise making it publicly available.  
​​
Responsibilities of ROs:

a. Forward media inquiries they receive to their designated contact in the regional Office of Public Affairs (OPA) for review and guidance on responding.
 
b. Notify the National Office of Job Corps before, or simultaneous to, providing notice to OPA.

R5. Media Related Events

Responsibilities of federal contractors and others operating Job Corps centers concerning media related events are below.
a. Provide the RO advance written notice of planned events or activities where media interest or participation might exist.  This notice should include information sufficient for Job Corps and others to assess the level of media interest (e.g., type of event, date, location, participants, type of media interest or participation is anticipated, and any concerns related to the media’s interest or participation in the event).

b. Advise media organizations that Job Corps prefers they only interview students 18 years of age and older.
 
c. Provide written notice to students in advance of a media visit to their Job Corps center.  The notice must inform students that they are not required to appear in media coverage or broadcasts, and can refuse to speak or be interviewed, filmed, photographed, or otherwise recorded during a media visit.
  
d. Refrain from taking disciplinary actions against students that limit the exercise of their First Amendment protections.  These protections include, but are limited to, initiating media contact and publishing information about the Job Corps program.

R6. Center Visits by Elected Officials

Job Corps wants to be transparent about center operations while also ensuring student privacy, minimizing disruptions to normal center operations.  From time to time, Federal, state and local elected officials may request tours or visits to Job Corps centers.  Job Corps seeks to accommodate those requests whenever possible.    

​Federal contractors and others operating Job Corps centers often extend or receive unsolicited requests for tours or visits of centers.  These entities cannot grant elected officials or their staff permission to tour, visit, or speak at Job Corps centers without prior notice and approval by the Department of Labor (DOL).  The notice and approval process is outlined below. 

a. The center operator must submit a written approval request to the RO.  When possible, the center operator must submit the request at least ten business days before the proposed visit by the elected official or his/her staff. 

b. The approval request must describe the purpose of the visit or appearance, and what news media, if any, may attend or accompany the official.
  
c. Job Corps’ RO must notify the National Office of Job Corps of the requested visit.  Job Corps’ National Office will coordinate review of the request with DOL’s Office of Congressional and Intergovernmental Affairs and OPA.  The National Office of Job Corps will also ensure that the RO and center operator are advised of any DOL visit guidance and requirements.
  
d. Center operators must comply with all DOL guidance and requirements for requested and approved visits by elected officials or their staff, including but not limited to the general prohibitions below.

​​​​1. Declared candidates for public office, including incumbents who have declared their intent to seek re-election, may not visit a Job Corps center for the purpose of campaigning at a Job Corps center.

2. Declared candidates for public office may not use the center, its grounds and facilities, and its staff or students for a campaign event or an event that could affect the candidate’s campaign, including debates and forums.

3. Declared candidates for public office may not use the Job Corps logo or other intellectual property associated with the Job Corps program for campaign materials, media, or any other purpose.

R7. Reporting

Center operators, federal agencies, and OA/CTS contractors shall submit reports in accordance with Exhibit 5-2 (Plan and Report Submission Requirements).

R8. 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.

 

 Forms

 
  
Attachment 4 - Quarter 2 and Quarter 4 Placement Appeal Form
Attachment 5 - Quarter 2 and Quarter 4 Earnings Appeal Form
 

 Exhibits

 
  
Exhibit 5-1 Standard Operating Procedures
Exhibit 5-2 Plan and Report Submission Requirements
 

 Appendices

 
  
Appendix 501 - Attachments
Appendix 501 Policies and Procedures for Job Corps' PY 2019 Performance Management System-Introduction
Appendix 501a Policies and Procedures for Job Corps' PY 2019 PMS-Center OMS
Appendix 501b Policies and Procedures for Job Corps' PY 2019 PMS-OA OMS
Appendix 501c Policies and Procedures for Job Corps' PY 2019 PMS-CTS OMS
Appendix 501d Policies and Procedures for Job Corps' PY 2019 PMS-CTT OMS
Appendix 501e Policies and Procedures for Job Corps' PY 2019 PMS-PIP