GOAL 1:  A PREPARED WORKFORCE 

1.  Issue:  The use of WIA funds and tracking WIA outcomes

Program Area: ETA WIA

Performance Goal: Goal 04-1.1A — Increase the employment, retention, and earnings of individuals registered under the WIA adult program. Goal 04-1.1C — Increase the employment, retention, and earnings replacement of individuals registered under the Workforce Investment Act Dislocated Worker Program.

Report Title: Substantial Funds Are Used for Training, But Little Is Known Nationally about Training Outcomes (GAO-05-650)

Date Completed: June 2005

Conducted By:  GAO

Program Impacts:  WIA funds used for training need to be clearly identified and tracked.

Findings:

1. Questions were raised about how WIA funds are being used and how much is being spent on training. 

2. Contributing to the concern about the use of WIA funds is the lack of accurate information about the extent to which WIA participants are enrolled in training activities.

Recommendations:

1. Determine the extent to which WIA funds are used for training.

2. Determine how local workforce boards manage the use of Individual Training Accounts (ITA).

3. Determine what is known at the national level about outcomes of those being trained.

Actions Taken:

1. DOL standardized the definition of 'participant exit' for purposes of assessing program performance across all programs implementing common measures.  States began implementing these changes as of July 1, 2005.  The revised reporting requirements will facilitate better information about outcomes for all training programs.

2. Through the newly revised Workforce Investment Act Standardized Record Data (WIASRD), DOL will be able to capture information on all participants who receive training in each program year, not just those who exit the program.

3. ETA implemented a data validation initiative in PY 2003.  ETA provides the states with software, handbooks, training and technical assistance to validate annual reports and provides a sampling mechanism to review a select number of files from each program for manual review.

Actions Remaining:

1. States will be required to validate annual reports and perform data element validation once a year to improve the quality of the data used to compute performance reports. 

2. ETA will develop acceptable error rates for each program.

Expected Completion:

1. This is an ongoing initiative.

2. PY 2006

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-650.

2. Issue:  Comprehensive access to the WIA one-stop system for persons with disabilities

Program Area: ETA WIA

Performance Goal: Goal 04-1.1A – Increase the employment, retention, and earnings of individuals registered under the WIA adult program.

Report Title: Labor Has Taken Several Actions to Facilitate Access to One-Stops for Persons with Disabilities, but These Efforts May Not Be Sufficient  (GAO-05-54)

Date Completed: December 2004

Conducted By:  GAO

Program Impacts: The WIA one-stop system may need to alter information tracking systems and relationships with disability-related agencies in order to meet comprehensive access requirements.

Findings:

1. ETA, OASAM’s Civil Rights Center (CRC) and ODEP have taken several actions to ensure comprehensive access to one-stops, but these efforts may not be sufficient.

2. DOL has not developed a long-range plan for how it will carry out its oversight and enforcement responsibilities beyond 2005.

3. The information DOL publishes on employment outcomes for people with disabilities is limited.

4. The performance measurement system may result in customers being denied services because local areas may be reluctant to provide WIA-funded services to job seekers who may be less likely to find employment.

Recommendations:

1. DOL should develop and implement a long-term plan for ensuring that the WIA one-stops comply with the comprehensive access requirements.

2. DOL should use the expertise of staff from CRC, ETA, and ODEP to ensure comprehensive access within the one-stop system.

Actions Taken:

1. In a letter signed by the chief executives of CRC, ETA and ODEP, DOL responded that the agencies will develop a comprehensive, long-term strategic plan to address the One-Stop system’s provision of services to people with disabilities, beginning with the development of an overall framework for the plan.

2. CRC, ETA and ODEP have instituted a workgroup which has met consistently since January 2005.  The Rehabilitative Services Administration, Social Security Administration and Veterans' Employment and Training Service have also begun to participate in the development of the plan. 

3. DOL has articulated the mission of the workgroup developing the inter-agency work plan as to promote excellence in service delivery for people with disabilities in the One-Stop Career Center system.  By promoting excellence, DOL seeks to:

• Ensure that people with disabilities have equal opportunity to benefit from the programs and services available through the system;
• Promote meaningful and effective career opportunities for people with disabilities.

    The multi-year strategic plan will include a coordinated implementation strategy that will:

• Identify, coordinate, and maximize the use of agency resources;
• Ensure compliance with applicable disability-related statutes and regulations; and
• Promote quality in service delivery for people with disabilities.

4. The workgroup has completed a draft of the initial framework, which will soon be placed into Departmental clearance and forwarded to GAO.   Given the breadth of the workgroup’s mission, the plan will be developed in phases.     

Actions Remaining:

1. The workgroup will develop a white paper proposing policies and strategies for Phase I of the work plan for approval by agency heads. The approved policies and strategies will be translated into a work plan. 

2. Monitoring progress and updating the plan.  

Expected Completion:

1. February 2006

2. Implementation, monitoring and strategic planning will be ongoing.  

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-54.

3.  Issue:  Increasing employer use of the workforce system one-stops 

Program Area: ETA WIA

Performance Goal: Goal 04-1.1A — Increase the employment, retention, and earnings of individuals registered under the WIA adult program. Goal 04-1.1C — Increase the employment, retention, and earnings replacement of individuals registered under the Workforce Investment Act Dislocated Worker Program.  Goal 04-4.1A — Build a demand driven system by increasing accessibility to workforce information

Report Title: Employers Are Aware of, Using, and Satisfied with One-Stop Services, but More Data Could Help Labor Better Address Employers’ Needs (GAO-05-259)

Date Completed: February 2005

Conducted By:  GAO

Program Impacts: Better information on employers’ use of the WIA one-stops would help ETA manage its resources and improve service.

Findings:

1. Awareness of local one-stops increases with employer size: about half of small, two-thirds of medium, and three-quarters of large employers know about their local one-stops.

2. Employers primarily use one-stop services to help fill job vacancies.

3. Three-quarters of employers who use one-stops are satisfied with the services they receive.

4. Most employers who use one-stop services would likely use them again; about one-third of employers who are aware of one-stop services, but have not used them, would consider using them in the future.

5. Many employers choosing not to use one-stops do so because they either rely on other resources or do not have enough information about the services offered.

6. DOL’s employer satisfaction measure does not provide enough information on the services employers use.

Recommendations:  DOL should require States to collect and report on employer use of the workforce system.

Actions Taken:

1. DOL proposed a comprehensive, streamlined reporting system for 12 different programs, which included a component for an employer record that proposed collection of information on workforce services assessed by employers. 

2. Based on comments received during a recent Federal Register Notice comment period, DOL is currently conducting a feasibility study for incorporating such a component in our reporting system.  This is expected to be completed during FY 2007. 

3. Through recently revised guidance for the WIA and Wagner-Peyser Act two-year strategic plan and the WIA, Wagner-Peyser, and Senior Community Service Employment Program unified plan, States were required to describe how they will actively engage businesses to inform service delivery approaches for all customers. The planning guidance also emphasized workforce information as a critical component of a demand-driven workforce system, and the role businesses play in providing labor market information and in identifying high-growth, high-demand jobs.

Actions Remaining:  Results of the feasibility study will be reviewed and based on study findings, decisions will be made on the final reporting design and implementation schedule.

Expected Completion:

1. December 2007

Additional Information: A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-259.

4.  Issue:  Obtaining good performance information on the WIA programs

Program Area: ETA WIA

Performance Goal: Goal 04-1.1A — Increase the employment, retention, and earnings of individuals registered under the WIA adult program. Goal 04-1.2A — Increase entrance and retention of youth registered under the WIA youth program in education or employment. Goal 04-1.1C — Increase the employment, retention, and earnings replacement of individuals registered under the Workforce Investment Act Dislocated Worker Program.

Report Title: Labor Should Consider Alternative Approaches to Implement New Performance and Reporting Requirements (GAO-05-539)

Date Completed: May 2005

Conducted By:  GAO

Program Impacts: Rushed implementation of the new reporting system could negatively affect data quality and compromise the potential benefits of proposed changes. Unless DOL ensures that data collection is done in a consistent manner, the information will not be comparable on a national level.

Findings:

1. While many states supported streamlined reporting, 36 states indicated that implementing ETA’s reporting system, as proposed, would be very burdensome.

2. DOL has underestimated the magnitude and type of changes the reporting system would require and the resources states would need to implement it.

3. The use of common measures could increase the comparability of outcome information across programs and provide a more complete picture of the one-stop system, but states will face challenges in making the required changes.

4. One of the common measures will replace the current WIA earnings measures for dislocated workers, which may be a disincentive for serving this population.

5. States have very little time to make changes before they must begin data collection and reporting.

6. DOL has not provided guidance in a timely manner for states to implement changes.

Recommendations:

1. Consider alternative approaches to reach the goals of the new reporting system, including (a) ongoing consultations with key stakeholders, (b) implementing changes in phases, and (c) pilot testing and evaluating changes before full implementation.

2. Help states and local areas develop the capacity to track all jobseekers in a consistent manner using one-stop services.

3. Use the first year of implementation as a test phase and work with states to identify promising practices in collecting and reporting this data; provide technical assistance to states that do not have this capacity.

Actions Taken:

1. As an alternative approach, DOL implemented revised reporting requirements on current Workforce Investment Act Standardized Record Data (WIASRD).  States began implementing these changes as of July 1, 2005 and collecting baseline data during PY 05.  This move was intended to facilitate the reporting of common performance measures across DOL’s employment and training programs. 

2. Through the newly revised WIASRD, DOL will be able to capture information on all participants who receive training in each program year, not just those who exit the program.  DOL cited past consultation with stakeholders, and will continue to consult with and provide technical assistance to representatives of the State and local workforce system. 

3. DOL is conducting a feasibility study in three States and two local areas to examine the changes needed at the state and local levels to meeting the proposed data collection requirements as originally proposed in the July 2004 Federal Register.  This will be completed during FY 2007.

Actions Remaining:  ETA is continuing to work with State agencies to develop a more complete reporting system that will provide greater comparability and understanding of performance information by using the same definitions for the measures, and enhanced information about all services provided.

Expected Completion:

1. This will be an ongoing action.

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/new.items/d05539.pdf.

5.  Issue:  The quality and outcomes of  programs in the nation’s apprenticeship system and DOL’s oversight

Program Area: ETA Apprenticeships

Performance Goal: Goal 05-1.1A — Strengthen the registered apprenticeship system to meet the training needs of business and workers in the 21^st Century.

Report Title: Labor Can Better Use Data to Target Oversight (GAO-05-886)

Date Completed: August 2005

Conducted By:  GAO

Program Impacts:  DOL will need to improve oversight of apprenticeship programs.

Findings:

1. Labor’s monitoring of programs it directly oversees has been limited.  In 2004 Labor reviewed only four percent of programs in the 23 states where it has direct oversight.

2. Limited staff constrained DOL’s ability to do more reviews.

3. DOL has not employed its database to generate information indicative of program performance, such as completion rates. 

4. Labor does not regularly review council-monitored states or collect data from them that would allow for a national picture of apprenticeships.

5. Formal reviews by DOL have been infrequent and not necessarily useful.

Recommendations:

1. Labor should better utilize its database for oversight — particularly for apprenticeship programs with expected future labor shortages.

2. Labor should develop a cost effective strategy for collecting data from council-monitored states for selected occupations.

3. Labor should conduct is reviews of apprenticeship activities in states that regulate their own programs on a regular basis to ensure that state activities are in accord with those requirements set forth by federal law, and offer substantive feedback.

Actions Taken:

1. The Department concurs with GAO’s recommendation on better utilizing the database.  ETA will use its existing data resources, as well as data from the Bureau of Labor Statistics (BLS), to identify occupations with skill shortages to help ETA better target Apprenticeship program performance and oversight activities.

2. In order to have the most complete national apprenticeship data possible, efforts underway have resulted in two additional State Apprenticeship Agency (SAA) states agreeing to participate in Registered Apprenticeship Information System (RAIS).  State of Kentucky started using RAIS in June 2005, and North Carolina is currently in the process of converting to RAIS.

3. ETA staff conducted and completed 14 SAA state reviews and 13 project reviews, including the District of Columbia during Fiscal Year 2005.

4. The Department agrees with the recommendation, and plans to offer substantive feedback to states after reviews.

5. ETA instituted an Apprentice Electronic Registration process for RAIS in October 2004.  This new feature is offered to SAA states as a cost-effective measure to improve data integrity and efficiency of apprenticeship data collection because the sponsor will enter the data.  ETA has been in negotiations with five SAA states since this process went on-line.

Actions Remaining:

1. ETA will seek input from DOL’s Advisory Committee on Apprenticeship regarding industry labor shortages.  ETA will expand its use of the Registered Apprenticeship Information System (RAIS) indicators along with implementation of WebCEO, a data mining tool.

2. Encouraged by early successes of Kentucky and North Carolina, ETA expects that other states will join RAIS.  Targeted resources are being utilized to make this a priority for the Department.

3. The Department’s goal is to complete the remainder of reviews in SAA states.

4. Final reports of the SAA reviews will provide additional feedback and technical assistance.

Expected Completion:

1. End of FY 2007

2. End of FY 2007

3. End of FY 2006

4. End of FY 2006

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-886. 

6.  Issue:  Understanding what supports the workforce development system needs to provide universal access to services for people with disabilities.

Program Area:  ODEP

Performance Goal:  Goal 05-1.1B — Provide national leadership to increase access and employment opportunities for youth and adults with disabilities receiving employment, training, employment support services by developing, testing and disseminating effective practices.

Report Title:  Case Study Research: How People with Disabilities are Served through the Workforce Development System

Date Completed:  September 2005

Conducted By:  Academy for Educational Development (AED)

Program Impacts: The study will document the actual challenges faced and strategies employed by 12 state and local workforce development systems (case study sites) in serving people with disabilities.  The identification of effective practices will be nationally disseminated.

Findings:

1. Leadership: Sites reported the need for effective and active Local Workforce Investment Boards (LWIB).  It is critical that leadership at the LWIB level set the tone and direction for serving people with disabilities.

2. Strategies of planning and support: Support from the disability navigator grant and other support agencies is critical in serving people with disabilities. However, there may be a caveat to this additional support. In many sites, the Navigators are being seen as the primary referral point for persons with  disabilities.

3. Collaboration: While many sites reported positive experience with the collaboration of their partners, vocational rehabilitation appears to be the most problematic.  In some cases, the One-Stops continue to view VR as the “automatic” referral for people with disabilities. To the extent of this belief, it is difficult for professionals to see the need to increase their capacity to work with people with disabilities. Another area of challenge in collaboration is the exchange of data. The sites reported that confidentiality requirements often prevented them from sharing information.

4. Accessibility and Assistive Technology: Many sites have made strides in making their facilities and equipment more accessible. The staff received training in how to use assistive technology equipment. The primary area of improvement needed is accessibility to programs. There is little evidence of widespread efforts to make all available programs accessible to people with disabilities.

5. Human Resources:  Sites noted the need for additional training and skill-building in the areas of connecting people to resources, improving administrative skills, and communicating effectively with people with disabilities.

6.  Data and Quality Assurance: The sites reported that the accountability system does not require data that accurately identifies all of the people with disabilities served. In addition to data collection, the sites experience a tremendous pressure to provide positive outcomes to satisfy the performance measures. This has caused an unintentional notion among the sites which encourages the “pre-screen” of people with disabilities in order to select those that will satisfy the performance measures.

Recommendations:

1. Review all current LWIB professional development curriculums and training activities for LWIB members.  Develop a national curriculum for LWIB members which require training on how to serve people with disabilities.

2. Define the role of Navigators. Clearly state that they are to provide consultative services to other staff and not to provide direct services to customers.

3. Initiate efforts to bring to scale the similar support services deemed to be effective.

4. Develop and disseminate concise descriptions regarding Vocational Rehabilitations “order of selection” process for serving individuals with disabilities to WIA partner agencies.

5. Develop the capacity of all WIA and other agencies within the workforce development system, both at state and local levels, to work effectively with individuals with disabilities.

6. Develop federal policy that allows for the sharing of information only for the purpose of improvement in service delivery.

7. Require all sites to carry out a comprehensive review and, if necessary, modification of their operating procedures to ensure accessibility.

8. Continue professional development for staff, in regard to effectively communicating with individuals with disabilities and skills such as resource mapping, cross-agency collaboration and service delivery, and disability etiquette. 

9. Increase the scope of training providers to other disability specific organizations and agencies such as Independent Living Centers, Parent Training and Information Centers, and educational facilities.

10. Implement a pilot data collection project designed to collect data that would present a more comprehensive profile and an accurate count of individuals with disabilities being served.

11. Develop and pilot alternative performance measures that are enhanced to allow for the complexities of serving individuals with disabilities.

Actions Taken:  No actions taken.

Actions Remaining:

1. Since the report is newly completed, the program is now beginning to review the recommendations and determine the next steps.

2. ODEP will provide a briefing to the interagency workgroup composed of ODEP, ETA, and OASAM’s Civil Rights Center. 

3. The interagency workgroup will determine how to use the information from the report as they develop a strategic plan to increase accessibility of workforce development programs, as recommended in a 2005 report from GAO.

Expected Completion:

1.  December 2005

2.  December 2005

3.  June 2006

Additional Information:  A copy of the complete report can be obtained from Richard L. Horne, Ed.D, Supervisory Research Analyst, ODEP, 200 Constitution Ave., NW, Room S-1303, Washington, D.C.  20210; (202) 693-7880.

7.  Issue:  The need for a web-based tool to help transitioning service members find civilian employment

Program Area:  VETS

Performance Goal:  Goal 04-1.1D — Improve employment outcomes for veterans who receive One-Stop and homeless veterans’ program services

Report Title: Feasibility Assessment of a Web-Based Career Guidance Tool for Transitioning Military Service Members

Date Completed:  June 2005

Conducted By:  Personnel Decisions Research Institute

Program Implication:  Since no single existing web-based tool meets the needs of transitioning service members and veterans, it will be necessary to customize a tool that will include career tips, a search function and details on civilian occupations.

Findings:

1. There is a need for a career guidance tool for transitioning service members.

2. It is feasible to design a tool that would meet the specific career information needs of key groups.

3. It is feasible — both from a content and a technology standpoint — to develop and implement such a tool.

Recommendations:

1. It is important to produce and implement a useful product that serves the needs of key stakeholders as quickly as possible, with features requiring longer-term research and development added later.

2. To build a successful tool, it is critical to have a solid understanding of service members’ needs and to gather feedback from them at several points in the development process.

3. Develop strategies to promote the use of the Career Guidance Tool.

4. The tool must be maintained and updated; regular data updates from the Defense Management Center will be critical for developing and maintaining search capabilities.

Actions Taken:  Findings have been shared with the Departments of Defense and Veterans Affairs

Actions Remaining:  Review with other agencies to determine next steps.

Expected Completion:  June 2006

Additional Information:  A copy of the complete report can be obtained by contacting Veterans’ Employment and Training Service, FPB S-1325, 200 Constitution Avenue, N.W., Washington, DC 20210, or by calling 202-693-4700.

8.  Issue:  A new performance accountability system for the Disabled Veterans’ Outreach Program (DVOP) and the Local Veterans' Employment Representative (LVER)

Program Area:  VETS

Performance Goal:  Goal 04-1.1D — Improve employment outcomes for veterans who receive One-Stop and homeless veterans’ program services

Report Title: Preliminary Observations on Changes to Veterans' Employment Programs (GAO-05-662T)

Date Completed: May 2005

Conducted By:  GAO

Program Impacts:  More work needs to be done to implement a minimum standard for veterans entering employment that all states will be expected to meet.  Until the standard becomes available, it is difficult to assess how well DVOP and LVER staff are performing.

Findings:

1. VETS has established newly defined roles for DVOP and LVER staff as required by the Jobs for Veterans Act (JVA) and provided guidance and training.

2. Almost half of the states plan to use JVA authority to assign DVOP staff on a part-time basis.

3. Integrating DVOP and LVER staff into one-stop centers remains a long-standing challenge.

4. VETS has implemented changes to its system for monitoring state compliance; work continues to determine how best to use the monitoring information to improve program performance.

Recommendations:  None made.

Actions Taken:

1. Findings discussed at the VETS National Office level and with a special VETS workgroup that addresses DVOP and LVER issues.

2. VETS has committed to set a national “minimum performance level” under the new Common Measures.

3. VETS has initiated a review of its grant based measures system.

4. VETS anticipates a revamped set of measures during PY 2005.

Actions Remaining:

1. VETS plans to conduct a nationwide study of DVOP/LVER programs in order to develop programmatic initiative recommendations for better integration into one-stop centers.

Expected Completion:

1. September 2006

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-662T.

9.  Issue:  Assessing the effectiveness of the Homeless Veterans’ Reintegration Project (HVRP)

Program Area:  VETS

Performance Goal:  Goal 04-1.1D — Improve employment outcomes for veterans who receive One-Stop and homeless veterans’ program services

Report Title:  Job Retention Goal Under Development for DOL’s Homeless Veterans’ Reintegration Program (GAO-05-654T)

Date Completed: May 2005

Conducted By:  GAO

Program Impacts: In order to assess the effectiveness of HVRP prior to reauthorization, the program needs to be able to develop and implement a goal for employment retention.

Findings:

1. DOL’s expenditures for HVRP grants have increased from $9.5 million in fiscal year 2000 to over $18 million in fiscal year 2004.

2. DOL estimates that it will expend over $20 million each year on HVRP grants in 2005 and 2006.

3. DOL has not developed a performance goal for a job retention measure and has not provided the Congress with statutorily required reports on program effectiveness.

Recommendations:

1. Because employment retention is crucial to the overall success of transitioning veterans from homelessness, it is important that DOL continue to develop a realistic performance goal for employment retention to assess the success of HVRP.

Actions Taken:

1. VETS is collecting and analyzing retention data for HVRP during PY 2004.

2. VETS has informed HVRP grantees of the need to place homeless veterans in jobs with maximum employment retention potential.

Actions Remaining:

1. VETS will use the retention data that is being collected to establish a baseline for future performance targets and tracking.

2. VETS will issue guidance for implementing the new performance targets.

Expected Completion:

1.  July 2006

2.  July 2006

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-654T.

10.  Issue:  Meeting the needs of service members leaving the military

Program Area: VETS Transition Assistance Program (TAP)

Performance Goal:  Goal 04-1.1D — Improve employment outcomes for veterans who receive One-Stop and homeless veterans’ program services

Report Title:  Enhanced Services Could Improve Transition Assistance for Reserves and National Guard (GAO-05-544)

Date Completed: May 2005

Conducted By:  GAO

Program Impacts: The program needs to determine when and where to offer the TAP for members of the Reserves and National Guard, especially since they have been called to active duty in greater numbers than at any time since the Korean War.

Findings:

1. The federal agencies have taken actions to improve TAP’s content and increase participation.

2. TAP faces challenges serving Reserve and National Guard members because of their rapid demobilization.

3. DOL is assessing its employment workshop curriculum using focus groups and survey data.

4. DOL provides some workshops and briefings overseas.

5. DOL has pilot programs in three states that will offer employment workshops after members return home.

Recommendations:   DOD, in conjunction with DOL and the U.S. Department of Veterans Affairs should determine what demobilizing Reserve and National Guard members need to make a smooth transition and explore options to enhance their participation.

Actions Taken:  DOL is participating in a DOD led effort to determine the best way to provide services to Reserve and transitioning National Guard members.

Actions Remaining:  Collaborating with the Department of Defense in order to report back to Congress.

Expected Completion:

1.  December 2005

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-544.

11.  Issue:  Developing baseline values for efficiency and earnings gain measures for veterans

Program Area:  VETS 

Performance Goal:  Goal 04-1.1D — Improve employment outcomes for veterans who receive One-Stop and homeless veterans’ program services

Report Title:  Developing Efficiency and Earnings Gain Measures

Date Completed: September 2005

Conducted By:  SRA International, Inc.

Program Impacts: Obtaining and analyzing data on the post-program earnings experiences of veterans served by the Labor Exchange will enable VETS to establish baselines and future targets for program performance.

Findings:

1. Developing baseline values for efficiency measures had to avoid potential double counting of veterans because both a DVOP and an LVER serve the same veteran.

2. Job seeker data were not available prior to PY 2002 to identify veterans served by DVOP or LVER.

3. A number of states appear to have different strategies and thresholds for reporting who received staff-assisted services, a key tracking variable.

4. Data suggest a positive baseline value for veterans served by DVOP or LVER, but it is difficult to say precisely what that positive value should be.

5. Additional analyses, perhaps conducted by States, can provide further insights.  Selection of zero as the baseline value for average earnings gains may not change, but one could select it with greater confidence.

Recommendations:

Good candidates for efficiency measures are:

1. Cost per individual who received a staff-assisted service (all participants).

2. Wagner-Peyser cost per individual who received a staff-assisted service (non-veteran).

3. DVOP/LVER cost per veteran who received a staff-assisted service.

4. Cost per individual who entered employment (all participants).

5. Wagner-Peyser cost per individual who entered employment (non-veteran).

6. DVOP/LVER cost per veteran who entered employment.

Actions Taken:

1. Background information from the study was utilized in deciding on an efficiency measure for the DVOP/LVER program.

2. "Cost per veteran participant" has been adopted for immediate implementation as the efficiency measure for the DVOP/LVER program.

Actions Remaining:   Once a Common Measures definition is adopted, VETS will use the study’s findings on "earnings gain" measures to establish baselines.

Expected Completion:

1.  September 2006

Additional Information:  A copy of the complete report can be obtained by contacting Veterans’ Employment and Training Service, FPB S-1325, 200 Constitution Avenue, N.W., Washington, DC 20210, or by calling 202-693-4700.

12.  Issue:   The compliance of Job Corps contractors with laws, regulations, policies and procedures relating to operating costs

Program Area: ETA Job Corps

Performance Goal: Goal 04-1.2B — Improve educational achievements of Job Corps students and increase participation of Job Corps graduates in employment and education.

Report Title: Performance Audit of Job Corps Center Operating Costs (OIG 03-05-004-03-370)

Date Completed: March 2005

Conducted By:  OIG

Program Impacts: ETA is taking steps to ensure that Job Corps Centers’ financial reports accurately reflect operating costs and expenses.

Findings:

1. Overall, Job Corps contractors are complying with laws, regulations, and Job Corps policies and procedures related to center operating costs.

2. Three areas of noncompliance that related to specific contractor operations were identified:

• Inadequate accounting systems
• Discrepancies between the ETA-2110 and the Public Voucher
• Compensation in excess of statutory limitations.

3. At several centers, journal entries were unauthorized, inadequately supported or incorrectly recorded.

Recommendations:

1. ETA should require the contractor for the North Texas Job Corps Center (JCC) to:

• refund $786,977 because these costs were not shown to be reasonable and allowable
• use a current cost method to prepare the ETA-2110 financial report
• take the necessary steps to ensure there is support for the amounts reported on the ETA-2110.

2. ETA should ensure that:

• financial reports and billings by the former contractor for the Homestead JCC are accurate and complete
• Homestead JCC staff receive training on how to accurately prepare the monthly ETA-2110
• controls are implemented so that all future submissions are properly reconciled to the Public Voucher and the books of account.

3. ETA should require the contractor for the Treasure Island JCC to refund $38,235 paid in excess of Executive Level II compensation limits.

4. ETA should ensure that each center has written policies and procedures related to the preparation, documentation, recording, and approval of all journal entries made to the centers’ books of account and that corrective actions are taken by the five JCCs to address the deficiencies reported.

Actions Taken:

1. Job Corps was reimbursed by North Texas Job Corps Center for costs that were unreasonable.  The Dallas Regional Office is working with the center operator for North Texas JCC to use current cost methods to prepare financial reports. 

2. A trainer was also brought in to the North Texas Job Corps Center from an outside source to train and work with center to bring them into compliance.

3. The Contracting Officer for Homestead JCC now requires that center operator implement controls to ensure all future submissions are properly reconciled to the Public Vouchers and the books of account. 

4. The National Office of Job Corps is currently developing online and video training for all center operators to utilize with staff on financial reporting, particularly the 2110 financial reports.  There will be specific emphasis to make sure that the Homestead JCC takes part in the training.

5. Job Corps was reimbursed by Treasure Island Job Corps Center for costs paid to the Center Director in excess of Executive Level II compensation.

6. The Regional Office Contracting Officers and Project Managers for the five centers noted now require that the operators have written policies and procedures for the preparation, documentation, recording, and approval of all journal entries made to the centers’ books of account and that corrective actions be taken.

Actions Remaining:

1. Online training will be conducted with centers to assure proper preparation of the ETA-2110.

Expected Completion:

1. December 2005

Additional Information:  A copy of the complete report can be obtained at http://www.oig.dol.gov/public/reports/oa/2005/03-05-004-03-370.pdf.

13.  Issue:   The reliability of performance outcomes reported by center operators and Career Transition Services (CTS) providers

Program Area: ETA Job Corps

Performance Goal: Goal 04-1.2B — Improve educational achievements of Job Corps students and increase participation of Job Corps graduates in employment and education.

Report Title:  Job Corps Performance Measurement Outcomes Report (OIG 09-04-004-03-370)

Date Completed: September 2004

Conducted By:  OIG

Program Impacts: Job Corps has implemented procedures to correct management control weaknesses.

Findings:

1. Job Corps management controls over performance data reliability do not adequately address the increased financial risk created by the May 2002 implementation of performance-based contracting.

2. Job Corps did not effectively validate reported performance outcomes during onsite assessments conducted by Job Corps Regional Offices.

3. Job Corps’ written procedures do not require regional staff conducting onsite assessments to test the validity of reported performance outcomes.

Recommendations:

1. Test performance outcomes data reported by center and Career Transition Services providers during each onsite review using statistical sampling methodologies.

2. Retain records that document the testing performed and the basis for any conclusions.

3. Take appropriate actions to recover any overpayments made to the contractor as a result of misreported performance data.

Actions Taken:

1. Job Corps has taken steps to amend the Program Assessment Guide to include mandatory activities for testing the validity and reliability of performance outcome data.

2. Job Corps has developed and is testing a documentation system in support of the performance data evaluation testing model.

3. Job Corps is working to establish procedures and parameters for recovery of identified overpayment made to a contractor as a result of misreported performance data.

Actions Remaining:

1. Finalization of the documentation system and training of Federal and Regional staff.

2. Finalization and implementation of procedures and parameters for recovery of identified overpayments.

Expected Completion:

1. October 2005

2. January 2006

Additional Information:  A copy of the complete report can be obtained at http://www.oig.dol.gov/public/reports/oa/2004/09-04-004-03-370.pdf

14.  Issue:   Status of the BLS Consumer Price Index (CPI) information security program

Program Area: BLS Consumer Price Index System

Performance Goal: Goal 05-1.3A — Improve information available to decision-makers on labor market conditions, and price and productivity changes.

Report Title:  Federal Information Security Management Act Audit of the Consumer Price Index System (OIG-23-05-005-11-001)

Date Completed: March 2005

Conducted By:  OIG

Program Impacts: Effective controls over information systems are essential to ensuring the protection and availability of Federal government economic indicator data.  Under the Federal Information Security Management Act, OIG evaluated the effectiveness of the management, operational and technical security controls of the Consumer Price Index (CPI) System. 

Findings:

1. The CPI contingency plan is in draft format and has not been tested.

Recommendations:

1.  Finalize, approve, and distribute the contingency plan to key personnel.

2.  Make sure that all recovery team members are aware of their roles and responsibilities for system recovery.

3.  Ascertain that the equipment necessary to support the CPI contingency plan is purchased and placed into the recovery facility.

4. Test the Continuity of Operations Plan in accordance with DOL and National Institute of Standards and Technology requirements.

Actions Taken:  

1.  BLS has made progress toward finalizing and approving the CPI Contingency Plan.  The plan has been completed sufficiently to allow for testing.  Updates are made to the plan when additional information is presented. 

2.  Equipment necessary to support the CPI contingency plan has been purchased and placed into the recovery facility.

3.  The CPI Continuity of Operation Plan testing under their current technical testing plan has been completed.

Actions Remaining:

1.  Once the CPI Contingency Plan has been finalized and approved, it will be distributed to key personnel.

2.  Training for recovery team members will begin by the end of the fiscal year.

Expected Completion:

1. December 2005

2. September 2005

Additional Information:  A copy of the complete report can be obtained at the Bureau of Labor Statistics, Division of Management Systems, Room 4080, 2 Massachusetts Avenue, NE, Washington, DC 20212, or by calling 202-691-7628.

GOAL 2:  A SECURE WORKFORCE

15.  Issue:  The impact of DOL compliance assistance strategies

Program Area: ESA WHD

Performance Goal:  Goal 05-2.1A — American workplaces legally employ and compensate workers.

Report Title:Findings from Employers Pocket Guide on Youth Employment: YouthRules! Telephone Survey

Date Completed:  December 2004

Conducted By:  Westat

Program Implication: Identifying cost effective ways of providing employers with information on youth employment rules impacts WHD's ability to ensure safe workplaces for young workers and to educate employers of the youth employment laws.

Findings:

1. The information contained within the evaluated compliance assistance publication was not relevant to the majority of businesses in the census because they did not employ young workers.

2. Those who read the brochure found it valuable and thought it offered good compliance tips.

3. A small percentage of employers who where mailed the guide hired workers younger than 18 years and reported reading the guide.

Recommendations: None made.

Actions Taken:

1. Evaluation findings were communicated throughout the organization.

2. WHD’s field offices were encouraged to rely less heavily on non-targeted mass mailings as a form of compliance assistance, and directed to incorporate alternative methods of outreach into local initiatives during the annual planning phase.

Actions Remaining:

1.  Work completed; no additional actions planned at this time.

Expected Completion:

NA

Additional Information:  A copy of the complete report can be obtained from Wage-Hour Division, Employment Standards Administration, U.S. Department of Labor, FPB S-3502, 200 Constitution Ave., N.W., Washington, D.C. 20210, or by calling 202-693-0051.

16.  Issue:  The impact of DOL compliance assistance strategies

Program Area: ESA WHD

Performance Goal:  Goal 05-2.1A — American workplaces legally employ and compensate workers.

Report Title: The Fair Labor Standards Act: Executive, Administrative, and Professional Exemptions Seminar Evaluation

 Date Completed:  May 2005

Conducted By:  Westat

Program Implications: Identifying cost effective ways of educating employers about the Fair Labor Standards Act (FLSA) affects WHD’s ability to ensure workers receive fair and legal compensation.  Developing clear, useful compliance materials promotes compliance and an accurate understanding of the law.

Findings:

1. The seminar was informative and prompted attendees to perform additional research on overtime security laws.

2.  Most respondents reported learning some new information on all topics covered by the seminar.

3. Over 75 percent reported being satisfied with the seminar.

Recommendations:

1. Strengthen the seminar by increasing the number of examples presented and broadening the topic coverage.

2. Offer two versions of the presentation — introductory and advanced.

3. Ensure availability of prompt email and telephone responses to questions regarding the seminar.

4. Ensure the Web site is up-to-date regarding the exemption rule.

Actions Taken:

1. WHD considered possible future improvements to the FairPay Seminar, which would include industry specific examples of compliance issues as new policies are defined or clarified or as new compliance problems are identified through the agency’s compliance efforts.

2. WHD verified that the FairPay Web site is up-to-date and that email and telephone reply process were in place.

3. WHD has developed and disseminated through the organization abridged versions of the seminar.

Actions Remaining: No additional actions planned at this time.

Expected Completion:  NA

Additional Information:  A copy of the complete report can be obtained from Wage-Hour Division, Employment Standards Administration, U.S. Department of Labor, FPB S-3502, 200 Constitution Ave., N.W., Washington, D.C. 20210, or by calling 202-693-0051.

17.  Issue:  Budget and performance integration

Program Area: ESA WHD

Performance Goal:  Goal 05-2.1A — American workplaces legally employ and compensate workers.

Report Title: Budget and Performance Integration Model Evaluation

Date Completed:  October 2004

Conducted By:  ICF Consulting

Program Implications: Refining a model to integrate WHD’s budget and performance will improve cost effective management of resources.

Findings:

1. WHD is in the early stages of a successful budget and performance integration effort and the basic processes used by the WHD budget and performance integration model are appropriate, given the constraints under which they operate.

2. The current WHD budget/performance integration model uses a proportional distribution methodology to map non-investigative time and resources to WHD program goals. This is based on the assumption that the distribution of total costs is similar to the investigator hour’s distribution, determined by the database. In the absence of an activity-based cost system, this is a reasonable approach to allocate non investigative time and resources, but does not accurately reflect total costs required to achieve performance goals.

3. The current WHD model does not take full advantage of the capabilities of spreadsheet technology and may not utilize all of the actual data currently collected and available from existing systems.

Recommendations:

1. Include output measures in the model, in order to calculate unit costs for activities.

2. Use enhanced unit-cost data by calculating the fully loaded unit costs and direct unit costs of output measures, in order to determine if resources would be better spent on one performance goal or another.

3. Use object class codes to improve the precision of the allocation process.

4. Distinguish direct costs from other costs in the model to consider the impact of shifting resources from one performance category to another to meet performance goals.

5. Calculate regional costs and track performance throughout the year against the budget to better evaluate performance at the regional level.

6. Document the mechanics of the model and the data relationships to ensure that information is available to enable others to understand the mechanics of the model and the distribution approach.

7. Incorporate links and formulas in the model's spreadsheets to reduce data entry time and errors.

8. Identify all contract costs and collect staff travel time; assign them across all performance goals.

9. Incorporate the results of the DOL Cost Analysis Manager (CAM) survey into the model.

10. Explore the advantages/disadvantages of using: (a) dollar-weighted labor hours, (b) three-year averages, and (c) a correction step in the model.

Actions Taken:

1. Evaluation findings were communicated throughout the organization; some recommendations are still under consideration, such as using three-year averages, distinguishing between direct and other costs, and calculating fully loaded unit costs and direct unit costs of output measures.

2. Incorporated output measures into the model to calculate unit costs for activities.  All of the output measures developed for CAM are incorporated into the performance budget and can be identified in the "Summary of Performance and Resource Levels" table.

3. Used major object class codes to improve the precision of the allocation process.

4.  Incorporated the results of the CAM survey into the model.

Actions Remaining:

1. Document the mechanics of the model and the data relationships to ensure that information is available to enable others to understand the mechanics of the model and the distribution approach.

2. Incorporate links and formulas in the model’s spreadsheets to reduce data entry time and errors.

3. Improve the output measures in CAM to more accurately reflect unit costs.

Expected Completion:

1.  March 2006

2.  March 2006

3.  October 2005

Additional Information:  A copy of the complete report can be obtained from Wage-Hour Division, Employment Standards Administration, U.S. Department of Labor, FPB S-3502, 200 Constitution Ave., N.W., Washington, D.C. 20210, or by calling 202-693-0051.

18.  Issue:  Assessing the connection between the UI program and reemployment services

Program Area: ETA UI

Performance Goal:  Goal 05-2.2A — Make timely and accurate benefit payments to unemployed workers, facilitate the reemployment of Unemployment Insurance claimants, and set up Unemployment tax accounts promptly for new employees.

Report Title: Better Data Needed to Assess Reemployment Services to Claimants (GAO-05-413)

Date Completed:  June 2005

Conducted By:  GAO

Program Implications:  Although there are program specific tracking systems in place, there is no single, comprehensive database that tracks the extent to which all claimants are receiving reemployment services (including self-services) and the outcomes of those services. 

Findings:

1. Little data are available to gauge the extent to which UI claimants are receiving reemployment services or about the outcomes they achieve.

2. Information is generally collected on a program-by-program basis or is focused on a single category of claimants. This does not allow for a comprehensive, nationwide understanding of claimants' participation in the broad range of reemployment services provided through federal programs nor do they move states in the direction of having the data they need to better manage their systems.

Recommendations:

1. As part of the development of the ETA's Management Information and Longitudinal Evaluation (EMILE) system, the Department should work with states to develop a plan for considering the feasibility of requiring states to collect more comprehensive information on UI claimants' use of reemployment services and the outcomes achieved by claimants, including the length of time claimants receive UI before they are reemployed.

Actions Taken:

1. Developed a performance measure of the extent to which UI beneficiaries become reemployed.

2. Funded 21 States to conduct in-person Reemployment and Eligibility Assessments (REAs) with UI beneficiaries.

3. Requested additional funding for REAs in the FY 2006 budget.

Actions Remaining:

1. Issue instructions to States for reporting reemployment data.

2. Incorporate the reemployment measure into the performance measurement system.

3. Collect information from nine States on the results of the REAs.

4. Seek authority to collect data from all States funded for REA activity.

Expected Completion:

1. September 2005

2. April 2006

3. May 2006

4. February 2006

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/new.items/d05413.pdf

19.  Issue:  Gaining a better understanding of the UI program

Program Area: ETA UI

Performance Goal:  Goal 05-2.2A — Make timely and accurate benefit payments to unemployed workers, facilitate the reemployment of Unemployment Insurance claimants, and set up Unemployment tax accounts promptly for new employees.

Report Title: Unemployment Insurance. Information on Benefit Receipt (GAO-05-291)

Date Completed:  March 2005

Conducted By:  GAO

Program Implications:  The UI program, administered by ETA in partnership with states, plays a critical role in ensuring the financial security of America’s workforce.

Findings:

1. About 38 percent of workers born between 1957 and 1964 received UI at least once between 1979 and 2002, with almost half of these individuals receiving UI benefits more than once.

2. Another 39 percent of this age group of workers were eligible to receive UI benefits, but never did so.

3. Nine percent of all workers in this age group are estimated to have been unemployed at least once, but were never eligible for UI benefits, mostly because of the conditions under which they separated from their jobs.

4. UI receipt varied by industry and occupation.

Recommendations: None made.

Actions Taken: NA

Actions Remaining: NA

Expected Completion:  NA

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/new.items/d05291.pdf.

20.  Issue:  Difficulties obtaining workers’ compensation benefits for exposure to Agent Orange

Program Area:  ESA OWCP

Performance Goal:  Goal 05-2.2B — Minimize impact of work-related injuries.

Report Title: Limited Information is Available on the Number of Civilians Exposed in Vietnam and Their Workers’ Compensation Claims (GAO-05-371)

Date Completed:  April 2005

Conducted By:  GAO

Program Implications:  Meeting the needs of civilian federal employees exposed to Agent Orange during the Vietnam war may require changes to the (a) ways claims are processed, (b) dissemination of information to claimants, and (c) legislation.

Findings:

1. Claimants faced many difficulties and delays because of a lack of readily available information on how to file a claim, their Vietnam era employers, and their exposure to Agent Orange.

2. Claimants faced processing delays caused by employers, insurance carriers, and DOL.

3. Both DOL and private insurance carriers had difficulty identifying the number of claims they had received, largely because they do not assign a unique code to Agent Orange claims that would enable easy identification.

Recommendations:

1. DOL should enhance its processing and management of claims, including improving the information used to track claims.

2. DOL should maintain better information on the insurance carriers it licenses.

3. DOL should provide better information to claimants to use in filing claims.

Actions Taken:

1. The Longshore Case Management System (LCMS) was changed in March 2005 to record a unique nature of injury code for Agent Orange claims, as well as requiring that a country code for Vietnam is entered for each Agent Orange case.  The accuracy of the data entry will be subject to the performance measures and standards currently in place. 

2. The case management system for FECA is also being modified to accommodate the new identifiers. 

3. The Cleveland district office, where all special claims are processed, has been notified of the intent to use this new identifying information. 

4. The Longshore Program Web site has been enhanced to direct potential claimants to the existing Defense Base Act (DBA) question and answer web page where the information and forms for submitting claims are already available at  www.dol.gov.esa/owcp/dlhwc/DBAFaqs.htm.  The DBA Frequently Asked Questions section has been specifically updated with reference to claims arising from Agent Orange exposure in Vietnam. 

5.  Regarding the specific recommendation that information be posted on Vietnam era contractors, please see the GAO findings on the lack of surviving records with regards to Vietnam era employment records.  In view of this, we agree to preserve information we still have on Vietnam era employment.

Actions Remaining:

1.  Most of the claims activity and records pertaining to "Vietnam era employers" predates the automation of the Longshore Case Management System (LCMS) by many years.  The GAO reported that, "most agency records maintained during this period were not computerized, and because so much time has elapsed, many paper records have been destroyed and many agency personnel knowledgeable of the period are no longer working at these agencies." The GAO also documented similar difficulties common to the private insurance companies which had provided the coverage under the DBA.  Nevertheless, the Longshore Program has already committed to more closely enforce the coverage card submission requirement. An evaluation of the Longshore database is underway and enhancements to Longshore’s data capacity will result from that study.

Expected Completion:

1.  FY 2006

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/cgi-bin/getrpt?GAO-05-371.

21.  Issue:  Cost to the government of insurance coverage purchased under the Defense Base Act (DBA)

Program Area:  ESA OWCP

Performance Goal:  Goal 05-2.2B — Minimize impact of work-related injuries.

Report Title:Defense Base Act Insurance: Review Needed of Cost and Implementation Issues (GAO-05-280R)

Date Completed:  April 2005

Conducted By:  GAO

Program Implications:  DOL administers the DBA and must ensure that workers’ compensation benefits are provided to employees of government contractors working at U.S. defense bases overseas.

Findings:

1. The number of employees required to be covered under DBA while working in Iraq is significant. The State Department reported over 150,000 Iraqis were performing work in Iraq on U.S. government-administered projects.

2. Conditions in Iraq, such as mixed-funding sources for contracts and language barriers, have led to complications in implementing DBA.

3. Challenges include clarifying when DBA applies, providing adequate and accurate information to companies and workers, monitoring compliance, and processing claims.

4. There is confusion among federal agencies and contractors over DBA.

5. The Department of Labor is limited in the actions it can directly take for non-complying contractors.

6. Processing claims has been slowed by difficulty obtaining medical and personal information because of conditions in Iraq and the need to respect local customs. Attorneys involved in DBA issues also report difficulty obtaining necessary documentation, including contracts and marriage records, to file and report claims.

Recommendations:

1. GAO suggests that Congress consider requiring the Director of OMB to determine, in coordination with DOD, DOL, the State Department, and the U.S. Agency for International Development, current and future needs, options, and risks associated with DBA insurance.

2. The agencies involved in the coordinated effort should identify necessary actions, including legislative changes.

Actions Taken:

1. The Department of Labor has express a willingness to work with any other agencies on matters of DBA coverage should Congress determine that an interagency initiative is required.

Actions Remaining:

1.  To be determined by congressional action.

Expected Completion:1. Determined by congressional action.

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/new.items/d05280r.pdf.

22.  Issue:  Customer Satisfaction in follow-up to a Program Assessment Rating Tool (PART) recommendation to conduct more systematic program evaluations.

Program Area: EBSA, Office of Participant Assistance.

Performance Goal: Goal 05-2.2C — Enhance Pension and Health Benefit Security.

Report Title: Office of Participant Assistance Program Evaluation Studies 

Date Completed: February 2005

Conducted By:  The Gallup Organization

Program Impacts: The information gained through these studies continues to be instrumental in enabling EBSA to address program performance issues at the level that has the highest impact to effect change: the interaction that our customers have directly with EBSA personnel and representatives.  We have found that those employees who are most engaged with their customers are better able to ascertain situations that require the attention of the enforcement staff.  Being able to provide feedback to our employees on their strengths and weaknesses with respect to their customer interactions has been the key to continued program improvements. 

Findings:

Participant Assistance Customer Satisfaction Surveys and Mystery Shopper: 

1.  EBSA achieved a 62 percent customer satisfaction score (percentage rating 4 or 5 on a 5-point scale).

2.  EBSA has improved its customer satisfaction score each year since 2001, but variances still exist among offices and staff.

3. The program needs to convey that EBSA is willing to work with its constituents to ensure their needs are met. 

4. The Mystery Shopper study indicated significant improvement in the quality of interaction and technical competence.  Variance in technical competence did remain depending on subject matter.

Outreach Surveys: 

1. Most attendees and sponsors of outreach seminars rate overall satisfaction and usefulness favorably.

2. As in FY03, EBSA presenters are rated favorably for being knowledgeable and well informed, but the information is often found to be unclear and hard to understand.

3. Satisfaction varies widely by office.

4. “Presenter excellence” (defined as those receiving a 5 on the 5 point scale) varied greatly by type of program presented.

 Public Disclosure Room:

1. The Public Disclosure Room satisfies 73 percent of its customers.

2. Two performance attributes were identified as improvement priorities: "the clerk’s level of knowledge" and "the clerk’s ability to explain what would be sent."

3. Verbatim comments indicate that accessibility and timeliness of the material in the Public Disclosure Room are issues that need to be addressed.

Recommendations:

Participant Assistance Customer Satisfaction Surveys and Mystery Shopping:

1. Share individual results with Benefits Advisors and supervisors to aid in training.

2. Due to high percentage of "information only" calls, EBSA should focus improvement efforts on answering questions. 

3. Examine staff fitness for customer service role.

4. Focus on developing the best talents of each Benefits Advisor.

5. Set clear expectations and hold Benefits Advisors and Supervisors accountable for their service delivery.

6. Recognize and compensate for greatness.

Outreach: 

1. Examine organization and comprehensibility of presentations in relation to specific needs of different audiences.

2. Track specific presenters in the survey process as some are highly rated and others are not. 

Public Disclosure Room:

1.  Review results with Disclosure Room staff and develop an action plan for addressing performance.

Actions Taken:

Participant Assistance Program:

1. The Gallup Organization again conducted targeted training in each regional office based on their findings and conducted a focus group of the highest ranking Benefits Advisors to determine best practices. 

2. The Benefits Advisors in each office developed a plan for improving their office’s scores. 

3. Certain offices began experimenting with morale building events to recognize greatness as part of their action plans to improve service. 

4.  Regional Directors are now rated on whether or not they meet the current year goal for customer satisfaction. 

Outreach:

1. EBSA will continue to evaluate this service and relate updated findings to the presenters and offices conducting outreach. 

Public Disclosure Room: 

1. Results have been communicated to the Supervisor of the Public Disclosure Room for development of an action plan to address the issues identified in the study. 

Actions Remaining:

Outreach:

1. Public speaking training is being made available to those conducting outreach events to improve outreach performance.

2. Public Disclosure Room personnel have met to devise methods for improving service in the areas identified by the report and will continue to work toward improving performance.

Expected Completion:

1. Training to take place in FY 2006.  

2. Ongoing. 

Additional Information:  A copy of the complete reports can be obtained from the Employee Benefits Security Administration, 200 Constitution Avenue, N.W., Room N-5625, Washington, DC, 20210, or by calling 202-693-8655.

23.  Issue:  Office of Technology and Information Service — EFAST Data Accuracy

Program Area: Office of Technology and Information Service.

Performance Goal: Goal 05-2.2C — Enhance Pension and Health Benefit Security.

Report Title: EBSA Should Mandate Electronic Filing Of the Form 5500 to Improve Data Accuracy  (OIG 09-05-002-12-121)

Date Completed: September 2005

Conducted By:  OIG

Program Impacts: The ERISA Filing and Acceptance System (EFAST) is EBSA’s system for processing the Form 5500 reports.  The Form 5500 is the primary source of employee benefit plan information for both the Federal Government and the private sector.  EFAST processes approximately 1.2 million Form 5500s per year and distributes the data to the IRS, PBGC, and EBSA. The Form 5500 data provides the foundation for EBSA’s enforcement, participant assistance, and disclosure programs.  Maintaining accurate data is critical to achieving the program’s ambitious performance goals and EFAST is the locus of that data. 

Findings:

1.  EBSA has not ensured that its contractor, NCS-Pearson, met the data accuracy standards specified in the contract.

2.  Data from electronically filed Form 5500s met the data accuracy standards.

3.  EBSA has not received the quality for the price paid.

4.  Electronic filings processed by EFAST were significantly more accurate than paper filings but only constitute about 1 percent of filings.

5.  Agency user resources have been diverted to address data accuracy issues.

Recommendations:

1.  Mandate electronic filing.

2.  Consider withholding payment to NCS-Pearson if accuracy standards are not met.

3.  Include in future systems development contracts, specific remedies for noncompliance with data accuracy standards.

Actions Taken:

1.  EBSA supports mandating electronic filing of the Form 5500 and has issued a Notice of Proposed Regulation in the Federal Register on August 30, 2005.

2.  EBSA has considered withholding payment to NCSP if accuracy standards are not met but wants to ensure no unintended adverse consequences.  If adopted, this approach would have to be taken with the approval and assistance of the Offices of Procurement Services and Solicitor.

3.  EBSA will consider, and implement as appropriate, specific remedies for noncompliance with data accuracy standards in EFAST2.

Actions Remaining:

1.  As deliverables are received, EBSA will consider whether performance targets are met and  will consider withholding payment consistent with the contract.

2.  Contingent on EFAST2 funding approval, EBSA will implement, as appropriate, remedies for noncompliance with data accuracy standards.

Expected Completion:

1.  On-going

2.  On-going

Additional Information:

A copy of the complete report can be obtained from the U.S. Department of Labor Office of Inspector General, 200 Constitution Avenue, N.W., Washington, D.C. 20212 or from http://www.oig.dol.gov/.

24.   Issue:  Providing timely information on private pension and other employee benefit plans

Program Area: EBSA and PBGC

Performance Goal:  Goal 05-2.2C — Enhance Pension and Health Benefit Security. Goal 05-2.2D — Improve service to pension plan customers.

Report Title: Government Actions Could Improve the Timeliness and Content of Form 5500 Pension Information (GAO-05-491)

Date Completed: June 2005

Conducted By:  GAO

Program Impacts: DOL will need to coordinate with the Internal Revenue Service (IRS) and PBGC to overcome processing delays and the lack of critical information on multiemployer plans. 

Findings:

1. Statutory reporting requirements, processing issues, and current DOL practices affect the timeliness of the release of Form 5500 information about private pension plans, resulting in a three year lag.

2. Form 5500 is filed 98 percent of the time in a paper format. These take more than three times as long as electronic filings to process and have twice as many errors.

3. The release of Form 5500 information in the research file is further delayed because DOL waits until all filings for that plan year are processed, which can take up to two years.

4. Form 5500 still lacks key information that could better assist DOL, IRS, and PBGC in identifying and tracking all plans over

    time and monitoring multiemployer plans.

Recommendations:

1. Require electronic filing of Form 5500.

2. Modify DOL processing methods to improve timeliness, reduce errors, and maximize efficiency.

3. Evaluate ways to speed up the release of the research file, including making interim information available prior to the final release to the public.

4. Modify Form 5500 to collect additional information on multiemployer pension plans.

Actions Taken:

1. The Department of Labor, the IRS, and PBGC are working to implement a mandatory, wholly electronic system for the receipt and processing of Form 5500 data to improve timeliness and reduce errors.

2. PBGC is actively pursuing actions to obtain much of the multiemployer data mentioned by GAO.  A decision, however, has not yet been made to add these questions to the Form 5500.

Actions Remaining:

1. DOL, IRS, and PBGC will continue to work to implement electronic Form 5500

    processing

Expected Completion:

1. Work will continue throughout FY

    2006.

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/cgi-bin/getrpt?GAO-05-491.

GOAL 3:  QUALITY WORKPLACES

25.  Issue:  Improving performance monitoring and the selection of cases for inspection

Program Area: OSHA

Performance Goal: Goal 05-3.1A — Reduce work-related fatalities. Goal 05-3.1B — Reduce work-related injuries and illnesses.

Report Title: Safety in the Meat and Poultry Industry, while Improving, Could Be Further Strengthened (GAO-05-96)

Date Completed: January 2005

Conducted By:  GAO

Program Impacts: Program performance could be better assessed and inspections could be targeted more effectively if changes are made to data systems.

Findings:

1. The meat and poultry industry still has one of the highest rates of injury and illness of any industry. The most common injuries are cuts, strains, cumulative trauma, and injuries sustained from falls, but more serious injuries, such as fractures and amputation, also occur.

2. Evidence suggests that OSHA’s efforts have a positive impact on injury/illness rates in meat and poultry plants.

3. OSHA could improve its selection process for inspection by considering plants’ injury and illness rates over time.

4. It is difficult to assess the effectiveness of OSHA’s efforts because the agency does not assign a unique identifier to each plant, making it hard to compare the data on injury/illness rates with information collected through inspections.

Recommendations:

1. OSHA should consider adjusting its criteria for selecting plants for inspection and audit to include those that have had large reductions in their injury and illness rates over time.

2. OSHA should change the way it collects data on plants in order to make it easier to measure the impact of its programs.

Actions Taken:

1. OSHA has solicited public comments on its Site Specific Targeting (SST) program; we are currently reviewing comments from industry associations, employers and safety and health professionals.

Actions Remaining:

1. Upon completion of the review of the SST comments, OSHA will consider expanding the criteria for SST inspections in the meatpacking industry.

2. OSHA will consider expanding data-collection efforts for multiple years for trend analysis, inclusion of recordkeeping submittals to capture contract workers illness and injuries, linking the IMIS and other data processing systems to come up with unique identifiers.

Expected Completion:

1. April 2006

2.  FY 2006

Additional Information:  A copy of the complete report can be obtained at www.gao.gov/cgi-bin/getrpt?GAO-05-96.

26.  Issue:  Identifying Nationally Recognized Testing Laboratories (NRTL) to perform safety testing/certifications.

Program Area: OSHA

Performance Goal: Goal 05-3.1A — Reduce work-related fatalities. Goal 05-3.1B — Reduce work-related injuries and illnesses.

Report Title: OSHA Correctly Denied ED&D’s Incomplete NRTL Application (OIG 05-05-002-10-001)

Date Completed: March 2005

Conducted By:  OIG

Program Impacts: Changes to Nationally Recognized Testing Laboratories (NRTL) review and audit procedures will improve OSHA’s process of selecting organizations to conduct safety testing and certification.

Findings:

1. OSHA’s decision to deny Education Design and Development, Inc. (ED&D) NRTL recognition was justified because ED&D did not meet all the elements required for recognition.

2. OSHA’s records adequately supported its decision to grant recognition to several organizations ED&D alleged were given recognition inappropriately.

3. OSHA permitted some applicants to self-certify they were independent and did not verify these statements.

4. OSHA did not appropriately handle ED&D’s application in two areas, but these deficiencies did not adversely affect the outcome of the application.

Recommendations:

1. OSHA should make independence review a mandatory part of application reviews and periodic audits.

2. Modify current policy to ensure that all areas related to an NRTL’s recognition are reviewed at least once during each five-year recognition period.

3. Review two NRTLs’ current business practices to ensure conformance with the independence requirement.

4. Ensure that incomplete applications are closed.

5. Maintain a log of contacts with the applicants and NRTLs.

6. Develop procedures to acknowledge all requests for feedback.

Actions Taken:

1. OSHA is revising and supplementing its procedures for verifying an NRTL’s independence.

2. OSHA is developing procedures to ensure review of NRTL’s recognition requirements every five years.

3. OSHA procedures will be adhered to ensure that incomplete applications are closed.

4. OSHA is now using a phone log for tracking substantive contact with NRTL applicants and will develop tracking tools to capture all contacts with applicants or other parties.

6. OSHA is augmenting its current controls for acknowledging all requests for feedback.

Actions Remaining:

1. Final implementation of new policy and revised procedures for reviewing  independence and other areas.

2. Review of the independence of two NRTLs.

3. Final implementation of chronological log referred to in Actions Taken #4.

4. Final enhancements to procedures for feedback request acknowledgement, referred to in Actions Taken #5.

5. Review of two specified NRTL’s for independence are planned.

Expected Completion:

1.  March 2006

2.  September 2006

3.  September 2006

4.  September 2006

5.  September 2006

Additional Information:  A copy of the complete report can be obtained at http://www.oig.dol.gov/public/reports/oa/2005/05-05-002-10-001.pdf.

27.  Issue:  Evaluation required by Section 610 of the Regulatory Flexibility Act and Section 5 of Executive Order 12866

Program Area: OSHA

Performance Goal: Goal 05-3.1A – Reduce work-related fatalities. Goal 05-3.1B – Reduce work-related injuries and illnesses

Report Title:  Regulatory Flexibility Act Review of the Occupational Safety and Health Administration’s Ethylene Oxide Standard. 

Date Completed: March 2005.

Conducted By:  OSHA

Program Impacts: Regulatory review indicates the ethylene oxide standard has been effective in reducing exposures and achieving health benefits.

Findings:  OSHA determined that the Ethylene Oxide standard should be continued without change.

Recommendations:

1. As a result of the review and comments received, OSHA will enhance its compliance assistance materials on the subject.

Actions Taken:

1. OSHA has initiated a review of its guidance materials in order to enhance compliance assistance information

Actions Remaining:

1. Development and publication of clarified guidance material.

Expected Completion:

1.  December 2006

Additional Information:   A copy of the complete report can be obtained at http://www.osha.gov/dea/lookback.html#Completed%20Lookback%20Reviews

28.  Issue: The impact of OSHA’s Voluntary Protection Programs (VPP)

Program Area: OSHA

Performance Goal: Goal 05-3.1A — Reduce work-related fatalities. Goal 05-3.1B — Reduce work-related injuries and illnesses

Report Title:  Evaluation of the Voluntary Protection Program

Date Completed: September  2005

Conducted By:  The Gallup Organization

Program Impacts: This report provides OSHA with models and formulas to project the participation benefits of the Voluntary Protection Program (VPP). With this information, OSHA is able to measure VPP’s value accurately, demonstrate the programs’ benefits, and promote program growth.

Findings:

1. The draft study indicates that VPP sites may have a leveraging effect in their dissemination of safety and health knowledge through outreach and mentoring conducted by the sites to other establishments in like industries, both within their own corporations and outside.

2. The draft study measured injury and illness rates at the respondent VPP sites and documented overall reductions from the time of the early decision and inception phase to full participation in the VPP process.  These data will be available to OSHA for further analysis, in response to the GAO recommendation that OSHA obtain data on VPP sites for analysis.

3. The draft study documented a model and provided data from a limited number of responding sites, estimating the costs and benefits of VPP.  This model could be used as the basis for a broader sampling and in-depth evaluation of the national program.

Recommendations:

1. OSHA should continue to use and build upon the data gathered for this evaluation to strengthen the data analysis capabilities for the VPP and other voluntary programs.

Actions Taken:

1. Preparations are being made to disseminate the study to VPP managers for analysis and opinion.

2. Information from the study will be presented to companies expressing interest in the program.

Actions Remaining:

1. OSHA will consider broader uses of the study’s models and formulas for future standardized assessments of VPP effectiveness.

Expected Completion:

1. 4^th Quarter, FY 2006.

Additional Information:   A copy of the complete report can be obtained at http://www.osha.gov.

29.  Issue:  Providing services to and tracking injury, illness, and fatality rates for independent contractors

Program Area: MSHA

Performance Goal: Goal 05-3.1A — Reduce work-related fatalities. Goal 05-3.1B — Reduce work-related injuries and illnesses

Report Title:  Evaluation of the Mine Safety and Health Administration’s Efforts to Deliver Services and Support to Miners Working for Independent Contractors

Date Completed: September 2005

Conducted By:  Research Triangle Institute (RTI)

Program Impacts: The increased use of independent contractors by mine operators creates unique workplace safety and health challenges.  Consequently, MSHA is seeking ways improve the delivery of its enforcement, educational, and technical support activities at independent contractor operations.

Findings:

1. Mine operators may use independent contractors to lower their costs and liability, and increase staffing flexibility.

2. Fatality rates for contractor employees are higher.  However, accidents and non-fatal injuries may be underreported in some cases, and there is incomplete information on contractor employee work hours at the mine level.

3. Contractor work on mine property is transient and temporary in some cases, and some independent contractors may have multiple mine identification numbers.  These factors, combined with the lack of contractor employment data by mine site, limits MSHA’s ability to provide compliance and educational assistance to independent contractors and accurately measure program impacts.

Recommendations:  None made.

Actions Taken:  MSHA is developing plans to improve its ability to obtain more accurate data on the hours worked by independent contractors and for delivering support and services to independent contractors.

Actions Remaining:

1. MSHA will respond to the GAO recommendation to collect hours worked by  independent contractors at the mine-specific level.

2. MSHA will develop a plan to improve services to independent contractors.

Expected Completion:

1. FY 2006

2. FY 2006 (MSHA revised Strategic Plan)

Additional Information:   A copy of the complete “interim” report can be obtained from the Mine Safety and Health Administration at 1100 Wilson Boulevard Street, 21^st Floor, Arlington, VA 22209-3939 or by calling 202-693-9607.

30.  Issue:  Selecting establishments for compliance reviews

Program Area:  ESA OFCCP

Performance Goal:  Goal 05-3.2A — Federal contractors achieve equal opportunity workplaces.

Report Title:  An Evaluation of OFCCP’s Equal Opportunity (EO) Survey

Date Completed:  March 2005

Conducted By:  Abt Associates Inc.

Program Implication: Targeting establishments that are most likely to be involved in systemic discrimination should improve the cost effectiveness of efforts to increase regulatory compliance.

Findings:

1. Four main predictor variables seem to be related to the presence or absence of system discrimination:

• whether the establishment reported more than 200 full-time employees
• the ratio of average tenure among minority employees to average tenure among non-minority employees
• the absolute value of the difference between the proportion of female employees and the proportion of male employees in EEO-1 Category 3 (technicians)
• the ratio of female-to-male tenure ratio to the median of those ratios in the establishment’s comparison group.

2. The model fits the data reasonably well and has acceptable predictive ability, although alternative approaches are possible.

3. Systemic discrimination was found in only about 3 percent of establishment reviewed; thus screening on the basis of the predicted probabilities would be expected to produce large numbers of false positives.

4. The ability to use a model and data from the Equal Opportunity (EO) Survey may be strengthened by more extensive cleaning of submitted data.

Recommendations:

1. OFCCP could select a stratified random sample of establishments for compliance reviews. 

2. Data provided by contractors at the desk audit stage of the review could be used to develop specified data elements.

3. Over several years, OFCCP could accumulate a substantial amount of data, consisting of the compliance reviews and corresponding data elements similar to those collected by the EO Survey.

4. This approach has the advantage of collecting more accurate and more pertinent data than provided by the current EO Survey.

Actions Taken:

1. Based on the final report, OFCCP prepared a document, summarizing the findings from the Abt report and outlining options for the next steps.

Actions Remaining:

1. Potential interactions with the compensation analysis initiative and the finalization of the applicant issue will be considered and next steps determined.

Expected Completion:

1.  December 2005

Additional Information:  More information may be obtained from the Office of Federal Contract Compliance Programs, Employment Standards Administration, Department of Labor, FPB N-3402, 200 Constitution Avenue, N.W., Washington, DC 20210, 202-693-1109.

31.  Issue:  Finding a data system to support timely information and interagency cooperation

Program Area:  ESA OFCCP

Performance Goal:  Goal 05-3.2A — Federal contractors achieve equal opportunity workplaces.

Report Title:Evaluation of the OFCCP Prototype Construction Contractor Information System (CCIS)

Date Completed:  November 2004

Conducted By:  ERG

Program Implication: A secure web-based information system for construction contractors would improve the cost effectiveness of OFCCP’s information collection and reporting on construction awards.

Findings:

1. There is strong evidence that the prototype CCIS can be implemented nationally to establish a universe of construction contractor information based on the best available data.

2. CCIS would provide OFCCP with a solid foundation for implementing a methodology that supports neutral selection of construction contractors for compliance review.

3. Using the GSA's Federal Procurement Data System-Next Generation (FPDS-NG) as a data source raises some difficulties that would need to be resolved.

4. To accomplish national implementation, OFCCP would need to fully integrate the system with data sources and prepare for an expanded user community.

5. Estimated startup costs for implementation of the national CCIS are in the range of $165,000-$210,000.

6. Estimated first-year operating costs are in the range of $60,000-$70,000.

Recommendations:

1. In the short term, OFCCP could implement CCIS using F.W. Dodge data only.  Even though Dodge data include fewer data elements that FPDS-NG, OFCCP already has routine access to these data.

2. In the longer term, it appears that CCIS would be most useful if tied into the evolving FPDS-NG and related E-Government initiatives. 

Actions Taken:

1. The structural framework for a database system has been completed. 

2. Start up and operational costs have been determined. 

3. The prototype is currently under review.

Actions Remaining:

1. OFCCP will not develop and disseminate guidance to District and Regional offices regarding the use of sources for selecting construction contractors for compliance evaluations until decisions are made on the prototype CCIS. 

2. Additionally, the proposed meeting with GSA to discuss the feasibility for accessing FPDS-NG contract information has been pushed back to the end of FY 2005.

Expected Completion:

1.  September 2005

2.  September 2005

Additional Information:  More information may be obtained from the Office of Federal Contract Compliance Programs, Employment Standards Administration, Department of Labor, FPB N-3402, 200 Constitution Avenue, N.W., Washington, DC 20210, 202-693-1109.

32.  Issue:  The employment needs of National Guard and Reserve members returning from active duty

Program Area:  VETS

Performance Goal:  Goal 05-3.2B — Reduce employer-employee issues arising from service members’ military obligations conflicting with their civilian employment.

Report Title:  Survey of USERRA Issues for Returning Military Members

Date Completed:  October 2004

Conducted By:  K.W. Tunnell Company, Inc.

Program Implication: Identifying patterns of difficulty experienced by Guard and Reserve members returning from active service will assist VETS in meeting the statutory Uniformed Services Employment and Reemployment Rights Act (USERRA) requirements.

Findings:

1. There is considerable evidence that the protections of USERRA work most of the time; many employers make considerable efforts to be supportive.

2. There are some problem areas and these are increasing as more Guards and Reservists are called to active duty; over 40 percent of respondents reported difficult gaining assistance with USERRA issues.

3. There needs to be a systematic approach and multiple briefings on job issues prior to active duty.

4. VETS staff members are often asked informally to answer questions and resolve complex issues, such as pension and health care benefits, for which they need additional training.

Recommendations:

1. Implement and monitor an Annual Briefing Plan, identifying how every customer will be briefed several times each year.

2. VETS should extend the briefing materials and consider using a briefing evaluation form.

3. Improve the USERRA Web site with deeper content on specific issues.

4. Provide a one-stop telephone hotline with experts on specific issues, such as pensions, health insurance, and training. Customers need to know that ongoing information and assistance is always available; all customers should know how to access such information and assistance.

5. Provide training and information support for VETS field personnel and state agency representatives.

Actions Taken:

1. VETS is closely monitoring Guard and Reserve mobilizations and demobilizations in each State.

2. Nationwide mobilization and demobilization schedules are being consolidated monthly.

3. VETS is delivering USERRA briefings to affected Guard/Reserve members at either mobilizations or demobilizations or both, as time and resources permit. The consolidated schedules help Regional and  Headquarters staff plan the briefings.  

4. The VETS Web site was enhanced during FY 2005 with the addition of the Electronic Form 1010 — an online function available to the public which references USERRA information.  This enhancement enables anyone to directly file an official USERRA claim online and open a USERRA case with VETS.

5. VETS field personnel are receiving information on complex issues from qualified USERRA practitioners in their State, or in other States, other Regions, or VETS Headquarters.

Actions Remaining:

1. All other recommendations are still pending consideration and possible action.

Expected Completion:

1. FY 2006

Additional Information:  A copy of the complete report can be obtained at the Veterans' Employment and Training Service (VETS), Room S1316, U.S. Department of Labor, 200 Constitution Avenue, Washington, D.C. 20210, or by calling Keenan Torrans at 202-693-4731

33.  Issue:  The trends and patterns found in 55 mid-term and final evaluations of DOL-funded projects implemented  by the International Labor Organization’s International Program on the Elimination of Child Labor (ILO-IPEC)

Program Area: ILAB

Performance Goal: Goal 05-3.3A — Contribute to the elimination of the worst forms of child labor internationally

Report Title: Comparative Assessment of ILO-IPEC Evaluation Reports Since 1995

Date Completed: April 2005

Conducted By: Academy for Educational Development

Program Impacts: The design, implementation, and monitoring of new and ongoing child labor-elimination projects can be enhanced through a synthesis of findings and recommendations of past project evaluations.

Findings:  This assessment synthesized finding and recommendations from the 55 evaluation reports.

Recommendations:

1.  Use national rather than international staff as main project implementers in the future.

2.  Give more attention to sustainability of projects in their design and implementation.

3.  Remove bureaucratic overload by reducing the number and frequency of progress reports.

Actions Taken:

1. ILAB is pressing grantees to first consider national staff before proposing international experts as key project personnel.  In cases where international experts are proposed, ILAB will request that grantees justify their choice.  ILAB is taking this action not only to improve the cost efficiency of projects, but also to build local capacity to eliminate the worst forms of child labor and promote project sustainability.

2. The greater the government involvement and commitment, the greater the chance that project successes will be sustained after the project ends.  ILAB is, therefore, giving funding priority to projects in countries where governments are involved     and committed to the project objectives.  ILAB is taking particular note of instances where governments contribute financial or in-kind support to the projects.

3. ILO-IPEC plans to update ILAB regularly on the status of project sustainability efforts through a separate section of upcoming technical progress reports.

4.  ILAB will address the issue of sustainability at all grantee meetings in Fall 2005 and Winter 2006.

5.  ILAB has reduced the reporting frequency for its child labor projects from quarterly to semi-annually for low-risk grantees.

Actions Remaining:

1. ILAB will continue to work with ILO-IPEC on these recommendations from the evaluation reports and on future recommendations.

Expected Completion:

1. ILAB will continue to work with ILO-IPEC.

Additional Information:  A complete copy of the report can be obtained from ILAB’s International Child Labor Program at GlobalKids@dol.gov  or by calling (202) 693-4843.

GOAL 4:  A COMPETITIVE WORKFORCE

34.  Issue:  Identifying contractual responsibilities and action of contractors assisting with researching the impact of the proposed and final overtime rule

Program Area: ESA WHD

Performance Goal:  Goal 05-4.2A — American workplaces legally employ and compensate workers.

Report Title: Fair Labor Standards Act:  Labor Made Key Decisions in Studies of Updated Overtime Rule and Contractor Provided Support

Date Completed:  June 2005

Conducted By:  Government Accountability Office (GAO)

Program Implications: Reports on the cost/benefit analysis of WHD’s new overtime security rule.

Findings:  GAO found that CONSAD Research Corporation, in accordance with its contract, provided DOL with technical and analytical support and that DOL made all of the key decisions in estimating the impact of the updated overtime rule.  

Recommendations: None made.

Actions Taken: NA

Actions Remaining: NA

Expected Completion:  NA

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/new.items/d05580r.pdf.

35. Issue:  The implementation of Trade Adjustment Assistance (TAA) reforms, changes in the demand for TAA training, and program effectiveness

Program Area:  ETA TAA

Performance Goal:  Goal 05-4.1B — Increase the employment, retention, and earnings replacement of workers dislocated in important part because of trade and who receive trade adjustment assistance benefits.

Report Title:Reforms Have Accelerated Training Enrollment, But Implementation Challenges Remain (GAO-04-1012)

Date Completed:  September 2004

Conducted By:  GAO

Program Implication:  DOL needs to monitor the new TAA provisions and proposed legislation if there is a negative impact.

Findings:

1. Most workers are enrolling in services more quickly than in prior years.  DOL reduced its average petition-processing time from 107 days to 38 days.

2. Due to a new deadline for enrolling, some workers may be negatively affected because it does not always leave enough time to assess workers’ training needs.

3. States reported challenges implementing some new provisions of the TAA Reform Act.

4. Demand for TAA training increased substantially in fiscal year 2002, prior to the implementation of reforms. However, States have struggled to meet this higher demand with available TAA training funds, even though funds available doubled nationally between fiscal years 2002 and 2003.  Most states have responded by using other Federal employment and training resources.

Recommendations:

1. Monitor the implementation of certain provisions of the TAA Reform Act and propose legislative changes if:

• The new training enrollment deadline is negatively affecting some workers, or
• The eligibility criteria for the new wage insurance provision are resulting in denial of services to some older workers who could benefit from them.

Actions Taken:

1. DOL has convened a summit of select States to discuss TAA Reform Act implementation issues.

2. DOL is conducting a review of implementation and post-implementation issues to gauge whether there has been positive change over time, with a particular focus on the collection of information relating to the training enrollment deadline as well as the eligibility requirements for the wage insurance program for older workers, known as the Alternative Trade Adjustment Assistance (ATAA) program. 

Actions Remaining:  The Department will utilize the information gleaned from all of the activities discussed above, as well as information provided in the GAO report, as we move forward on the development and implementation of a work plan to address these issues.

Expected Completion:

1. December 2006

Additional Information:  A copy of the complete report can be obtained at http://www.gao.gov/new.items/d041012.pdf.

36.  Issue:  The completeness and reliability of the CY 2003 data used to support the FY 2003 performance goal 2.3B

Program Area:  ETA TAA

Performance Goal:  Goal 4.1B — Increase the employment, retention, and earnings replacement of workers dislocated in important part because of trade who receive trade adjustment assistance benefits.

Report Title:  GPRA Data Validation Review, Trade Adjustment Assistance Program (OIG 22-05-007-03-330)

Date Completed:  September 2005

Conducted By:  OIG

Program Implication: DOL relies on accurate and complete participant data, submitted quarterly by the states, to assess whether or not the TAA program is achieving its yearly goals and if changes are needed to make it more accurate.

Findings:

1. The OIG verified seven data elements to source documentation found in participant files.

2. The "date of exit" data element could not be verified because it was recorded as an anticipated date, not the last data of services as required by TAA guidelines and because the State Workforce Agencies did not have source documentation to verify it.

3. Five of the seven verified data elements were dependent on the "date of exit" and, therefore, were not complete or reliable.

Recommendations:

1. The TAA Program should collect and record the participant’s actual "date of exit" according to ETA’s written definition.

2. The TAA Program should properly manage and maintain source documentation to support the actual "date of exit" and make it readily available for review.

Actions Taken:

1. ETA clarified the "date of exit" definition and issued a list of source documentation requirements for each of the data elements being validated.

2. In FY 2003, ETA implemented a data validation initiative for the Trade Act Participant Report (TAPR).

3. ETA has recently received OMB approval of a revision that reflects common performance measures and reporting definitions.

4. ETA completed a series of three national training sessions for all states on reporting definitions and documentation requirements for outcome reports, including TAPR.

Actions Remaining:

1. The TAA program will move to the common measures.

2. ETA intends to issue additional guidance to the states.

Expected Completion:

1. FY 2006

2. FY 2006

Additional Information:  A copy of the complete report can be obtained at http://www.oig.dol.gov/public/reports/oa/2005/22-05-007-03-330.pdf.