Appendix 3 Significant FY 2002 Audits and
Evaluations
1. Workforce Investment Act: Better Guidance and Revised Funding
Formula Would Enhance Dislocated Worker Program (GAO-02-274), February 2002
Agency: ETA
Conducted by: General Accounting Office
Recommendations: This report recommends that DOL: 1) Actively
identify areas that require additional assistance to help States and local
areas implement the dislocated worker program; 2) Disseminate guidance that is
more responsive to the concerns of workforce officials responsible for
implementing the Acts requirements, including when to register
individuals into the dislocated worker program and how to provide additional
assistance to local areas using rapid response funds; and 3) Disseminate timely
information on best practices being developed by local areas to meet the needs
of their dislocated workers.
Actions Taken: The actions proposed to address these concerns
are discussed in guidance issued by the Department in November, 2001. The
Department has also created and supported a National Dislocated Worker and
Rapid Response Workgroup that developed a number of technical assistance
products for use by staff in local workforce areas. These products are in
production and will be available in 2003. In addition, the Department developed
a contract to produce a website which will display best program practices
nationwide. Full implementation of the website is expected later in the year.
On the three-part formula for the dislocated worker program, the Department
initiated a study of the dislocated worker formula and fund distribution
process.
Additional Information: Available from the GAO website:
www.gao.gov.
2. Workforce Investment Act: Improvement Needed in Performance
Measures to Provide More Accurate Picture of WIAs Effectiveness (GAO-
02-275), February 2002
Agency: ETA
Conducted by: General Accounting Office
Recommendations: The report recommends that the Department: 1)
Delay the provision of financial assistance for at least one year or until
States have their data system in place to successfully track WIA outcomes; 2)
Expedite guidance on revising negotiated performance levels and allow States to
immediately begin the process of renegotiation; 3) Provide clearer guidance on
WIA registration for tracking proposes and work proactively with States to
implement guidance; 4) Continue to fully fund the Wage Record Interchange
System (WRIS) to assist with the sharing of Unemployment Insurance data across
state lines, and develop ways for States to share promising approaches in using
supplemental data sources to close Unemployment Insurance data gaps and improve
timeliness issues; 5) Ensure that development of optional One-Stop system
measures is completed so States can implement them in the beginning of PY 2002.
Actions Taken: The Department will take GAOs
recommendation into account when determining whether to impose financial
sanctions for under performance in PY 2002. Guidance on sanction policy was
provided (March 2000). Additional guidance on negotiation of performance levels
was issued to States (February 2002). The Department has also provided
additional funding for the Wage Record Interchange System (WRIS).
Additional Information: The full report is available from the
GAO website: www.gao.gov.
3. Workforce Investment Act: Interim Report on Status of Spending
and States Available Funds (GAO-02-1074), September 2002
Agency: ETA
Conducted by: General Accounting Office
Findings: GAO observed: (1) The Department lacks accurate
information upon which to base WIA funding decisions because of inconsistencies
in the way fund obligations are reported by States. (2) When obligations are
not considered, funding commitments made by States and localities are not
included, causing the Departments estimate of available funds to be
overstated. (3) Even with data limitations it is likely that the States will
easily spend their allocation within the three years allowed most of it
within the first 2 years. (4) To improve accuracy of financial reporting and
enhance the way they manage funds, States should seek more help from the
Department in the form of better definitions, better guidance and technical
assistance, and the systematic sharing of effective management strategies.
Actions Taken: ETA responded to the observations made in
this recent report but has not yet taken any action. ETA published a
clarification of reporting instructions on November 6, 2002 to address concerns
expressed to GAO and has committed to provide additional guidance and technical
assistance during the current year. This guidance and technical assistance will
extend to the proper accounting for Federal funds, clarification of reporting
requirements, and discussions of best practices relating to the effective and
timely spending of WIA allocations. A number of other recommendations made by
GAO could substantially increase the reporting burden and may not produce the
desired results. ETA believes these are more appropriately discussed as part of
the upcoming WIA reauthorization.
Additional Information: The full report is available from the
GAO website: www.gao.gov.
4. Workforce Investment Act: Youth Provisions Promote New Service
Strategies but Additional Guidance Would Enhance Program Performance
(GAO-02-413), April 2002
Agency: ETA
Conducted by: General Accounting Office
Findings:
- Nearly all local workforce investment boards nationwide established a
youth council and network of youth service providers, but not without
challenges.
- Youth councils established linkages with the education
community.
- Two factors improved coordination and delivery of services: having
experience in collaborative efforts among various public and private
youth-serving agencies and placing priority on youth development
- Three legislative requirements impeded progress: eligibility
documentation requirements, meeting the 30% requirement of funds to be spent on
out of school youth, and complex performance measures.
Recommendations: Issue guidance to assist boards and Youth
Councils in:
- Recruiting representatives for the Youth Council
- Increasing responses to Requests for Proposal
- Sharing client information among agencies to verify applicant
eligibility
- Recruiting and training out-of-school youth
- Facilitating linkages between boards and youth councils and their
youth-serving partner
- Collaborating with Dept. of Education and other experts to link
workforce and education activities
- Clarifying the definition of skill attainment for younger youth to
ensure consistency in reporting
Actions Taken: The Department disseminated youth council tool
kits on July 23,2002. Program Guidance for Implementation of Youth Services
under WIA was issued May 20, 2002, and provided guidance on a)
increasing/leveraging funding sources to better serve out-of-school youth; b)
developing and implementing strategies and service delivery priorities to
promote greater participation of faith and community based programs in delivery
of WIA youth services; and c) strategies for enhancing recruitment and
retention of out-of-school youth. The Department is still exploring sampling
methodology to ease eligibility requirements. Also, the Department has received
a draft final report on practices that enhance youth connections and access to
One-Stops. A National Youth Summit was held in June 2002, in collaboration with
the Department of Education. In preparation for WIA reauthorization, ETA has
conducted several national and regional forums and experts meetings, including
education representatives, to seek input and discuss and identify issues to
address in reauthorizing the legislation. The Department will clarify the
definition of skill attainment with the implementation of common performance
measures for job training programs in the 2004 budget.
Additional Information: The full report is available from the
GAO website: www.gao.gov.
5. Left Out of the Boom Economy: UI Recipients in the Late 1990s,
October 2001
Agency: ETA
Conducted by: Mathematica Policy Research (MPR), Inc.
Findings: Based on a nationally representative sample of 3,907
UI recipients who established a UI benefit year in 1998 (1,864 of whom
exhausted benefits), the study found that UI claimants on average took longer
to find reemployment, had higher exhaustion rates, and found new jobs replacing
less of their pre-unemployment wages than showed up in a similar study by MPR
ten years earlier. In part, these changes mirrored changes in the U.S. economy
generally (Unemployment durations have lengthened, claimants are older and more
likely to be minorities.) but also reflected declines in potential UI benefit
durations. Claimants were less likely to have registered with the Employment
Service or One-Stop than in 1988, and less likely to have received services
once registered, but more likely to have participated in training or education
to improve work skills. Services are well targeted on claimants at different
income levels and those who have exhausted benefits or were dislocated workers.
However, the authors consider low-skilled claimants relatively underserved
because their labor market outcomes were significantly worse than other
recipients despite receiving services at the same rate as higher-skilled
workers.
Recommendations: The study recommends that States (1) strengthen
job search requirements; (2) increase resources available to reemployment
services, and (3) ensure that low skill workers are targeted for reemployment
services by expanding the measures of skill level used in profiling.
Actions Taken: This research has been instrumental in helping
formulate possible ways of measuring entered employment of UI claimants as
indicators of the extent that the UI system facilitates UI claimants
reemployment. In March 2002, the Department distributed $8 billion in special
Reed Act funds to States and has urged the States to use some of these
resources for reemployment services.
Additional Information: The report can be found on the DOL web
site at: http://wdr.doleta.gov/owsdrr/ETA_occasional.asp
6. Unemployment Insurance: Increased Focus on Program Integrity
Could Reduce Billions in Overpayments (GAO 02-697), July 2002
Agency: ETA
Conducted by: General Accounting Office
Findings: Between September 2001 and May 2002, the GAO reviewed
internal Department guidance and documentation, performance plans and reports,
performance data relevant to the Departments oversight of the UI program,
and data from the Benefit Accuracy Measurement (BAM) and Benefit Payment
Control (BPC) systems; and they interviewed over 100 management and line staff
in the ETA national and Regional offices, in six state UI offices, and various
stakeholder organizations. They concluded that BAM estimates are better
indicators of the true levels and nature of overpayments than reported data on
BPC activities because they reflect all reasons for overpayments accurately,
and not only those that are administratively detectable or cost-effective to
establish for recovery. GAO determined that States do not sufficiently balance
the need to process and pay claims quickly with the need to control program
integrity, and rely too heavily on what claimants themselves report about their
eligibility for benefits. Further, the GAO believes the Department has also
emphasized payment timeliness over payment accuracy e.g., through its
choices of key performance measures and in the lack of incentives and sanctions
to promote accuracy. At the same time, the GAO commended the Department for
working to obtain data and conduct analyses that help States improve integrity,
and for its decision to develop a key payment accuracy measure for FY 2003.
Recommendations: The GAO recommends that the Department (1)
revise program measures to ensure increased emphasis on payment accuracy; (2)
develop incentives and sanctions that will encourage compliance with payment
integrity measures; (3) use its quality assurance (BAM) data more intensively
to help States identify internal policies and procedures that need to be
changed to enhance program accuracy; (4) help States increase the proportion of
overpayments they recover each year; and (5) study the potential for using the
Wage Record Interchange System (WRIS) to verify eligibility of persons claiming
interstate benefits.
Actions Taken: The Department has taken several actions
consistent with the GAOs recommendations. These include the development
of the proposed integrity measure; conducting several analyses of the causes of
UI overpayments and the benefits and costs of preventing, detecting and
recovering them; and instructing States to use New Hire data to inform BAM
overpayment estimates, and encouraging them to use new hires data to improve
the detection and recovery of overpayments due to claimants who continue to
claim benefits despite having returned to work. In June, ETA announced an
agreement with the Social Security Administration to give States real-time
access to the Social Security database. This will permit them to prevent many,
if not most, overpayments due to fraudulent or mistaken use of Social Security
Numbers (SSNs). UI payment integrity is a Federal emphasis area in the State
Quality Service Plan for FY 2003; States must explain how they intend to
address program integrity during the upcoming year.
Additional Information: The complete GAO report may be obtained
from the GAOs web site at www.gao.gov.
7. Audit of the Unemployment Insurance Data Validation Pilot Program
(OIG/OA Report 22-02-005-03-315), March 2002
Agency: ETA
Conducted by: Office of Inspector General
Findings: During 2001 and 2002, the OIG reviewed the UI Data
Validation (UI DV) program, which the Department will rely on to ensure the
accuracy of data used to compute key performance measures. States are now in
the process of implementing UI DV with a targeted completion date of July 2003.
The OIG audit involved reviewing the UI DV handbooks, related procedures for
handling reports data, and visits to two of the three UI DV pilot States
(Minnesota and North Carolina). The OIG concluded that the UI DV methodology is
sound and that it contains appropriate management controls to provide
reasonable assurance of valid reports data. They also identified two best
practices (Minnesotas use of Social Security query and cross match
procedures, and North Carolinas data extraction procedures.)
Recommendations: The OIG recommended that the Department (1)
establish written internal procedures to ensure the completeness of performance
reports data; (2) validate UI program performance data annually instead of on
the regular UI DV 3-year cycle; and (3) require reporting entities to retain
complete audit trails.
Actions Taken: The Department agreed with the OIG findings and
is taking steps to implement them. It has agreed to validate data used to
compute key GPRA performance goals annually, but notes that the annual
validation of data cannot begin until about FY 2005, after all States have
completed their first full validation.
Additional Information: The complete OIG audit report can be
found on the OIGs web site at
www.oig.dol.gov/public/reports/oa/2002/22-02-005-03-315.pdf
8. Findings and Recommendations to the Chief Financial Officer as a
Result of an Audit of the U.S. Department of Labors Principal Financial
Statements (OIG/ OA Report 22-02-004-13-001), March 2002
Agency: ETA
Conducted by: Office of Inspector General (OIG)
Findings: The OIG notes that UIs Benefit Accuracy
Measurement (BAM) data reflects little change in UI overpayment rates, and that
BAM data are not being used fully either to identify States with especially
higher overpayment rates or that are doing especially good jobs of preventing
or recovering overpayments. It considers that States need to improve their
internal controls over UI payments, and that DOL involvement is required if
they are to increase the prevention, detection and recovery of recoverable
overpayments they can detect through Benefit Payment Control (BPC) operations
(the Department estimates through BAM that these were roughly $1 billion in FY
2001).
Recommendations: The OIG recommends (1) a written plan to use
BAM data as the impetus for internal controls over the benefit payment process,
to include analysis procedures, methods to assist States in developing system
improvements, and monitoring of program improvement actions; (2) accelerated
efforts to use better systems to prevent and detect overpayments, such as new
hires data and the Social Security on-line Query System; (3) using the same
cause categories for BPC overpayments established as BAM uses for its
estimates, so that the effectiveness of BPC in establishing overpayments can be
better determined; and (4) perform a cost-benefit analysis of overpayments
identified as being difficult for BPC units to detect and to determine whether
additional resources should be devoted to such areas.
Actions Taken: The Department has taken several actions
consistent with these recommendations. It developed a multi-year plan to
address the identification of the causes of UI overpayments through more
detailed analyses, and to stimulate corrective actions by the States. Pursuant
to this work plan, it has conducted several analyses of the causes of UI
overpayments and the benefits and costs of preventing, detecting and recovering
them. A preliminary analysis concluded that the costs of detecting most types
of errors now undetected at the claims administration level exceed probable
recoveries. UI payment integrity is a federal emphasis area in the State
Quality Service Plan for FY 2003; States must explain how they intend to
address program integrity during the upcoming year. The Department has
instructed BAM units to use data from the State Directory of New Hires to
inform BAM overpayment estimates, and has encouraged States to use new hires
data to improve the detection and recovery of overpayments made to claimants
who continue to claim benefits despite having returned to work. In June 2002,
ETA announced an agreement with the Social Security Administration to give
States real-time access to the Social Security database. This will permit them
to prevent many, if not most, overpayments due to fraudulent or mistaken use of
Social Security Numbers.
Additional Information: The complete OIG audit report can be
found on the DOL/OIG web site at
www.oig.dol.gov/public/reports/oa/2002/22-02-004-13-001.pdf
9. Workforce Investment Act Performance Outcomes Reporting Oversight
(OIG/OA Report 06-02-006-03-390), September 2002
Agency: ETA
Conducted by: Office of Inspector General
Findings: The audit report raised concerns about whether the
third party data reported by states for WIA performance were accurate and
supportable.
Recommendations: OIG recommended that the Assistant Secretary
for Employment and Training: (1) continue ETAs efforts to establish a
standardized, statistical method for WIA performance data validation and
require States to use this method or a comparable one, (2) provide States with
consistent definitions and documentation guidelines, and (3) have ETA regional
representatives require states to validate data as part of their monitoring,
establish minimum documentation standards, and independently calculate reported
performance as part of state performance monitoring.
Actions Taken: The Assistant Secretary generally agreed with the
concerns raised by the Office of Inspector General, though not with each of the
recommendations. The response indicated that the Inspector General concerns
would be addressed with the deployment of a data validity and verification
policy and tools that have been under development and are scheduled to be
deployed in 2003.
Additional Information: The complete OIG audit report can be
found on the DOL/OIG web site at
www.oig.dol.gov/public/reports/oa/2002/06-02-006-03-390.pdf
10. Pension Welfare Benefits Administration: Opportunities Exist for
Improving Management of the Enforcement Program (GAO- 02-232), March
2002
Agency: PWBA
Conducted by: General Accounting Office
Findings: The GAO concluded that PWBAs enforcement program
is, overall, a well-run program. They identified certain weaknesses in
PWBAs management of its enforcement strategy and investigative process,
in its overall human capital management, and in its measures for addressing
program performance. GAO recommended actions to improve national oversight and
coordination and to address workforce issues.
Recommendations: (1) Develop a cost-effective strategy to assess
the level and type of ERISA non-compliance in employee benefit plans. (2)
Conduct regular reviews of the sources of cases that lead to investigations.
(3) Share best practices among regions on selecting and conducting
investigations. (4) Develop a closed case quality review process that ensures
the independence of reviewers. (5) Monitor and analyze barriers to
participation in the Voluntary Fiduciary Correction (VFC) program and find ways
to reduce them. (6) Conduct a comprehensive review of PWBAs future human
capital needs.
Actions Taken: (1) PWBA has recently completed a baseline
compliance study with respect to health care provisions of Part 7 of ERISA.
During FY 2003, PWBA will conduct a follow-up study of its FY 1995 baseline
study to assess the quality of employee benefit plan audits for Plan Year 2000.
(2) PWBA will conduct annual reviews of the sources of cases as resources
permit. A baseline review of FY 1999 data was issued October 31, 2001, and a
review of FY 2000 data was issued December 30, 2002. Work has already begun on
designing a study of FY 2001 and 2002 data. The FY 2000 analysis provided an
overview of the various types of investigations conducted by PWBA during FY
2000; identified which sources of investigations are most likely to result in
correction of a violation; identified which sources of investigations that
resulted in a corrected violation are most cost-effective, in terms of staff
years expended; analyzed the geographic coverage of the enforcement program
during FY 1999 and FY 2000; and, reviewed the Agencys Taft-Hartley
investigations. (3) PWBA is developing an Internet website to facilitate the
sharing of best practices. PWBA is also exploring other avenues for sharing
best practices. Suitable ideas will be presented to the Director of Enforcement
for consideration. (4) PWBA is finalizing a new quality review process that
will be implemented in FY 2003. (5) PWBA modified its VFC program taking into
account GAOs specific recommendations by expanding the scope of the
program, reducing the documentation requirements, and providing limited relief
from the excise tax imposed on prohibited transactions under the Internal
Revenue Code. (6) During FY 2003, PWBA will prepare a report of accomplishments
in the human capital management area that address the future human capital
needs identified by GAO. As part of the Departments Strategic Management
of Human Capital, the Department requested funding for FY 2003 to lead a
Department-wide, cross cutting initiative to conduct workforce analyses. PWBA
has submitted a proposal under this program. At this time, the Department is
considering PWBAs proposal and awaiting the final outcome of the FY 2003
appropriation. If PWBAs proposal is granted and funded, PWBA anticipates
using this preliminary workforce analysis as a basis for developing a more
comprehensive, strategic plan for human capital.
Additional Information: A copy of the complete report can be
obtained from the Pension and Welfare Benefits Administration, 200 Constitution
Avenue, N.W., Room N-5668 Washington, D.C., 20210. Please specify report #
GAO-02-232 dated March 2002. The report may also download it directly from
www.GAO.gov.
11. Market Landscape Analysis: Saving Matters Campaign and
Publications
Agency: PWBA
Conducted by: The Gallup Organization in collaboration with
Cone, LLC
Findings: (1) There is a need for focused, retirement savings
education. (2) Americans know saving is important, but they need to feel
empowered. (3) There is a lack of attention paid to American workers who need
and want retirement savings education. (4) Measurement of the effectiveness of
retirement savings education efforts is exceptionally difficult. (5) Many key
organizations are willing to collaborate on savings education but want their
goals and branded materials to be the focus. (6) The Saving Matters
campaign offers a base from which to grow. (7) DOL has an important role to
play in the retirement savings educational arena. (8) Department educational
campaign materials were found to be clearly presented and easy to understand
but the covers could be improved to increase the likelihood that the materials
would be opened. (9) There is pervasive misunderstanding of basic financial
management issues such as the tax benefits of a 401(k), risks associated with
long-term investment, and the positive benefits of saving early and compounding
interest.
Recommendations: (1) The campaign should: (a) have clearly
defined objectives, criteria, audiences, and mission statement, (b) focus on
workers and make retirement savings issues relevant, (c) educate on how to plan
and save for retirement, (d) increase understanding of retirement savings
options, (e) encourage taking action, (f) include a comprehensive approach with
focused and consistent messages and strong campaign voice, (h) leverage DOL
assets particularly field staff, (i) collaborate with select partners, (j)
establish measurable outcomes, and (k) target the underserved segment of
worker. (2) With respect to campaign publications, materials should: (a) focus
on educating workers with real examples of the tax benefits of retirement
savings vehicles, (b) demonstrate how saving small amounts compounds over time,
and (c) focus on how the market performs in the long term. (3) Recommendations
were made for distribution points to encourage individuals unlikely to seek out
information but who would be willing to read retirement savings information if
provided to them. (4) The Savings Fitness cover should be redesigned to include
DOL branding.
Actions Taken: (1) Findings were presented to the PWBA Regional
Executive leadership and Supervisory Benefit Advisors stressing the need to
focus on workers and develop evaluation criteria. (2) The Strategic Outreach
and Education Plan for Saving Matters for FY 2003 has been revised. (3) The
Department contracted with Gallup to develop measurable outcomes and to conduct
program evaluations in FY 2003, including potential use of pre and post surveys
to measure campaign effectiveness. Results of this initiative will not be
complete until late FY 2003. At that time, PWBA will review Gallups
findings and consider whether to incorporate them, as appropriate. (4) The
cover of the Savings Fitness booklet was redesigned to encourage individuals to
read the publication.
Additional Information: A copy of the complete reports can be
obtained from the Pension and Welfare Benefits Administration, 200 Constitution
Avenue, N.W., Room N-5668 Washington, D.C., 20210.
12. Introducing the Health Care Compliance Assistance Plan
Agency: PWBA
Conducted by: PWBA
Findings: After reviewing a representative sample of health
plans for compliance with the health care provisions of Part 7 of ERISA [e.g.
Health Insurance Portability and Accountability Act (HIPPA)] of 1996, Mental
Health Parity Act of 1996, Newborns and Mothers Health Protection
Act of 1996, and Womens Health and Cancer Rights Act of 1998), PWBA
found: (1) Generally, group health plans are in compliance with the substantive
provisions of the new health laws. (2) Implementation problems exist,
particularly with respect to certain requirements to provide notice to plan
participants as well as certain discrete substantive provisions that are
technical in nature.
Recommendations: (1) Develop and distribute additional
publications and other educational materials to improve compliance. (2)
Dedicate a section of the compliance assistance page on PWBAs website to
the new health care laws. (3) Participate in live workshops around the country
for the regulated community.
Actions Taken: PWBA has developed the HIPAA Compliance
Assistance Program (H-CAP) to improve compliance by partnering with the
regulated community to address problem areas identified in the Project. Under
the H-CAP initiative, PWBA is (1) publishing three new publications to assist
group health plans and health insurance issuers in complying with the new laws,
including a new Self-Audit Checklist, updated Compliance Tips, and a New Health
Laws Notice Guide. These materials will be distributed through PWBAs
toll-free publications line, at workshops and compliance assistance activities,
through industry groups and industry newsletters, the trade press, and the PWBA
website; (2) dedicating a new section of the web page to make it easier for
plans, issuers, and other service providers to find, in one location, all of
the regulations, publications, frequently asked questions, and other guidance
available; and (3) developing live workshops to be presented around the country
where trained staff will meet with plan administrators, plan sponsors, and
other service providers to apply the new Self-Audit Checklist to various sample
plan provisions.
Additional Information: A copy of the Health Disclosure and
Claims Issues: FY 2001 Compliance Project Report can be obtained from the
Pension and Welfare Benefits Administration by calling the toll-free
publications hotline at 1-866-275-7922 or by downloading it from the Internet
at: www.dol.gov/pwba.
13. Audit of the Federal Employees Compensation Act
Performance Measures System (OIG/OA Report 22-02-006-04-431), March
2002
Agency: ESA
Conducted by: Office of Inspector General (OIG)
Findings: The Office of Inspector General completed an audit of
the Federal Employees Compensation Act (FECA) programs performance
measures for Fiscal Years 1999 and 2000. The audits objectives were to
determine whether (1) the Division of Federal Employees
Compensations (DFECs) stated mission relates to its authorizing
legislation and reported performance measures reflect achievement of
legislative intent; (2) all FY 1999 and 2000 performance goals were measurable
and management controls existed over data reporting, appropriateness,
description, and definition; and (3) the full cost of accomplishing these
performance goals was developed.
The OIG found that the FECA program mission relates to its legislative
authority and that its FY 1999 and 2000 performance goals provided
accountability because goals were measurable and outcome oriented. In addition,
DFEC has been very active in coordinating the FECA program and activities with
other Federal agencies with crosscutting issues to achieve performance goals.
However, the OIG stated that management controls over data reporting,
appropriateness, description, and definition could be improved. Specifically,
OIG found that FECA customer satisfaction goal was not fully appropriate
because DFEC did not include employing agencies as a customer, the Lost
Production Days goal should include a definition for lost production
days, and management controls related to four of the goals would be
improved if written procedures were developed to document and describe data
collection and reporting procedures. Also, a system to identify the full cost
of accomplishing these performance goals a step necessary to comply with
Statement of Federal Financial Accounting Standards (SFFAS) No. 4 requirements
has not been developed.
Recommendations: The OIG commended DFEC for its efforts
to develop and implement a strategic and annual performance plan that reflects
its mission with outcome-based goals. To improve its goals and management
controls, the OIG recommended that DFEC should:
- Establish a performance goal for customer satisfaction that includes
employing agencies;
- Expand the description for performance for the Lost Production Days
goal to define lost production days.
- Define in writing how to calculate the quality index score for the
claims processing quality goal as part of the Accountability Review;
- Develop written procedures to explain how (and what sources are used)
to extract the data and make the calculations to report on the performance
measures; and
- Establish a time line for developing and placing in operation a
system that links performance measures, costs and the budget.
Actions Taken: OWCP generally concurred with the findings and
recommendations in the report. Actions taken include establishment of a
customer service goal that includes employing agencies; definition of
lost production days; definition of the quality index score
calculation; and written procedures explaining how data is extracted and
calculations made. The recommendation to establish a timeline to establish a
system to link budget and performance is unresolved; a corrective action plan
and timeline for completion was completed in December 2002.
Additional Information: The complete report can be found on the
OIGs website at www.oig.dol.gov/public/reports
/oa/2002/22-02-006-04-431.pdf
14. OSHA Data Initiative Collection Quality Control: Analysis of
Audits on 2000 Employer Injury and Illness Record keeping
Agency: OSHA
Conducted by: Eastern Research Group, Inc. and the National
Opinion Research Center
Findings: The data collected by the OSHA Data Initiative (ODI)
represent reasonable quality for OSHAs targeting and performance
measurement purposes. There has been a slight overall improvement among
employers in maintaining onsite log and hours worked data that are consistent
with information submitted to OSHA for the ODI. The percent of establishments
classified with accurate record keeping (at-or-above the 95 percent threshold)
is above 90 percent for both total recordable and lost workday injury and
illness cases.
Recommendations: Continue the audit program as a quality control
mechanism and use the information in outreach efforts to improve employer
injury and illness record keeping. Conduct an adjunct analysis to determine the
best method for assessing employer understanding of the revised record keeping
rule.
Actions Taken: OSHA will continue the Audit and Verification
Program of Occupational Injury and Illness and Illness Records, implement the
recommendations to improve the audit processes, and use the results to reach
out to employers to help them implement the new record keeping rule and to
improve their record keeping.
Additional Information: A copy of the report can be obtained
from the Occupational Safety and Health Administration, 200 Constitution Ave.,
NW, Washington, DC 20210 or by calling 202-693-2000.
15. Evaluation of the OSHA Consultation Program
Agency: OSHA
Conducted by: John Mendeloff, PhD., University of Pittsburgh and
Wayne Gray, PhD, Clark University
Findings: Through agreements with States, OSHAs
Consultation program funds State-provided, free safety and health consultation
visits to employers who request them. A consultation is associated with a 5.2%
decline in the establishments lost workday injury and illness rate (at
the 90% confidence level). Limiting the analysis to consultations that provided
a complete safety hazard assessment produced a larger (8.9%) decline in LWDII
rate. Inspections of establishments that had a consultation visit in the prior
2 years found significantly fewer serious violations, imposed penalties less
often, and imposed smaller penalties. Inspections with a preceding consultation
found an average of 0.66 fewer serious violations and assessed an average of
about $3,000 less in penalties.
Recommendations: Improve the quality of data submitted from
State Consultation Programs and encourage them to submit data from
consultations on a timelier basis. Conduct further investigation of possible
associations between consultation characteristics (such as type and duration of
services provided) and injury and illness rates.
Action Taken: OSHA is addressing the need to improve the quality
of the data submitted from the State Consultation Programs in FY 2003 through
its Integrated Management Information System redesign project. OSHA will assess
the impact of the consultation program by analyzing injury and illness data
from the OSHA Data Initiative for establishments that have received
consultation visits.
Additional Information: A copy of the report can be obtained by
writing the Occupational Safety and Health Administration, 200 Constitution
Ave., NW, Washington, DC 20210 or by calling 202-693-2000.
16. Workplace Safety and Health: OSHA Should Strengthen Management
of Its Consultation Program (GAO-02-60), October 2001
Agency: OSHA
Conducted by: The General Accounting Office
Findings: GAO identified factors that contribute to or detract
from small employers willingness to participate in OSHAs
Consultation Program. They also found weaknesses in OSHAs ability to
measure the success of the program and in its process for allocating program
funds to the States.
Recommendations: Restructure the formula for distribution of
funds to State consultation projects. Improve the measurement of the program
and better assess the impact of the program on worker safety and health.
Actions Taken: OSHA has revised its formula to allocate funds
based on performance criteria, and will use the new formula in FY 2003. OSHA
will address the other recommendations through the IMIS redesign project and by
analyzing injury and illness data from the OSHA Data Initiative for businesses
served by the consultation program. In addition, OSHA has implemented an
inspection deferral program, whereby employers working towards an effective
safety and health management system are granted up to 18 months deferral from a
programmed OSHA inspection. This inspection deferral program should increase
small business willingness to participate in the OSHA Consultation
Program. Finally, the funding formula rewards States that proactively seek out
and service small high-hazard employers, most likely resulting in increased
participation by small employers in OSHAs Consultation Program.
Additional Information: The complete report can be found on the
General Accounting Office website at www.gao.gov.
17. Worker Protection: Labors Efforts to Enforce Protections
for Day Laborers Could Benefit from Better Data and Guidance (GAO- 02-925),
September 2002
Agency: OSHA
Conducted by: The General Accounting Office
Findings: Current data on injury and illness may overlook
hazardous workplaces for day laborers. DOL uses injury and illness data
reported by employers to determine which industries and workplaces to target
for investigation. However, temporary staffing agencies are not required to
report such dataa responsibility that falls to the client
employersso OSHA cannot identify the extent to which day laborers working
through temporary agencies are injured or killed. GAO suggested that because
OSHA focuses its inspections on larger employers, smaller sites (where day
laborers are more likely to be employed) might be overlooked.
Recommendations: GAO recommended that OSHA enhance procedures to
reach day laborers, review local efforts to obtain additional data on the
presence and violation experience of day laborers working for temporary
staffing agencies, finalize its effort to collect data on fatalities, and
consider developing regulations to specify temporary staff agency
responsibility for safety and health.
Actions Taken: In response to the reports recommendations,
OSHA will continue to make a concerted effort to address issues related to day
laborers; OSHAs regional and area offices will continue working at a
local level with a variety of organizations faith-based, community,
academic and governmental to address the issues related to day laborers.
OSHA will also (1) continue exploring the best way to collect data on the
violation experience of day laborers, redesigning its current data collection
tool, Form 170 and (2) review interpretations for consistency and conformity
with current policy.
Additional Information: The complete report can be found on the
General Accounting Office website at www.gao.gov.
18. Performance Audit of Strategic Partnership Program Occupational
Safety and Health Administration for the Period January 1, 1995 through
February 28, 2002 (OIG/OA Report 05-02-007-10-001), September 2002
Agency: OSHA
Conducted by: Office of the Inspector General (OIG)
Findings: The Office of the Inspector General issued a report on
OSHA Strategic Partnerships (OSP). In an OSP, OSHA enters into an extended,
cooperative relationship with employers, employees, and employee
representatives. The objectives of the audit were to determine how effective
OSHA was in establishing OSPs through its outreach efforts, and if the
OSPs were making an impact in improving safety and health conditions in
the workplace. The OIG found examples of OSP successes, but they also found
that OSHA needed to improve data collection and program impact measurement,
increase program participation, and improve OSHA staff awareness of program
requirements.
Recommendations: Enlist more employers into OSPs, ensure
policies and procedures are communicated to all field offices, enforce the
requirement that program evaluation reports be completed annually, ensure
verification inspections are performed as required, share encouraging
preliminary results of the OSPs with potential participating employers,
explore procedures for obtaining information to corroborate Lost Work Day
Injury and Illness information, and correct and update the OSP log information
and transfer information to a database system.
Actions Taken: In response, OSHA expanded the database for
strategic partnerships by including additional data points, tracking
information, and general information that will enable it to better service and
assist small businesses. Additionally, OSHA did the following: improved data
quality; initiated analysis of OSP evaluation reports received through FY 2002;
increased coordination between personnel involved with the program at the
National, Regional and Area Office levels; and drafted a revised directive to
clarify program requirements that is currently being reviewed by OSHAs
field units.
Additional Information: The complete report can be found on the
Office of Inspector General website at
www.oig.dol.gov/public/reports/oa/main2002/05-02-007-10_001.pdf.
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