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General guidance on managing the WIOA ESE grant.

  • Follow the instructions here to submit a budget or project modification (e.g. budget realignment, administrative changes, statement of work changes, changes in key staff/contractors). The first step is to email EDD to consult options, see if a PMR is needed and if so, request the form.  Keep in mind the entire process takes up to 7-9 weeks.
  • WSD19-05 – Monthly and Quarterly Financial Reporting Requirements
  • Reports are due quarterly for all WIOA ESE grantees. Follow the instructions here.

Prior Written Approval

Prior written approval is required for purchases that fall under categories listed in page 4 of Directive 16-16. Written approvals must be obtained by grantees prior to the purchase of procurement valued over $5,000. To obtain approval, grantees must complete the Prior Written Approval Request form and submit to the EDD project manager email no less than 30 days before procurement action is scheduled to occur. For those that fall under the contracts category, approval is only needed for contracts with vendors not named in grant agreements. If you have any questions on whether a purchase requires written approval, reach out to the EDD project manager.

  • WSD18-05 WIOA Grievance and Complaint Resolution Procedures (Non-criminal violations)
  • WSD20-12 Incident Reporting (Fraud, Abuse or Criminal Conduct)
  • WSD17-01 Nondiscrimination and Equal Opportunity Procedures

While the chances of a incident arising during the grant term is very small, grantees of WIOA funding must establish procedures for participants to file grievances, complaints and incidents alleging violations of Title 1 requirements. ESEs must designate a staff member to handle complaints, and staff working on this grant must sign the policy acknowledging receipt and have it stored in their personnel file. The policies must be posted in a public location and made available to any interested parties or members of the public. WIOA-funded participants should be notified of the policy and a corresponding case note made on the participant’s account (no activity code needed).

If and when a complaint is filed, ESEs must provide a copy of their local procedures to each affected party, and include a signed copy of an acknowledgement of receipt in each participant’s case file. Incidents of fraud or criminal activity must be reported to the CRO within 1 workday. Given there are several steps associated with hearings, and state/national level escalation of grievances and incidents, ESEs should reach out to EDD and REDF immediately when a complaint or incident is filed so we can support their staff through the process.

If ESEs have an existing grievance and complaint policy and procedure, their compliance teams should review the directives to ensure their existing policy covers requirements and/or reference the examples below to examine what language needs to be added to their policies. If ESEs don’t have a policy, they should review the directives in depth and explore the resources below to develop their own policy and procedure for grievances. ESEs can also reach out to REDF for 1:1 support on this. 

 

Resources

  • WIOA Compliance Training Part 1 – Monitoring Process Overview & Major Risk Areas Recording and Presentation
  • WIOA Compliance Training Part 2 – Monitoring Checklist Walk Through Recording and Presentation
  • WIOA Discretionary Funding Monitoring Checklist Example. Note: This document serves solely as an example of a monitoring questionnaire for recipients of WIOA discretionary funding. Each program’s grantees is provided with their own unique questionnaire tailored to specific programmatic needs. The sample questions featured here may not be exhaustive, and the actual questionnaire’s scope is likely to expand beyond the provided content.
  • Sample Policies Templates for ESEs. Based on the list of policies outlined in the Monitoring Checklist Example above, REDF compiled templates of sample policies implemented by Local Workforce Development Boards for ESEs to adapt.

Expected Monitoring Process

  • EDD’s compliance team sends subrecipients an engagement letter with a program-specific questionnaire, and ask for samples (e.g. procedures, record keeping, notes, expenditures) to be ready for the onsite review. Usually a virtual meeting occurs prior to the onsite visit.
  • During the review week, EDD staff may interview grantee staff and has shifted their approach to providing onsite technical assistance in real time for staff to be compliant. EDD staff then have 25 days to release a report. If there are findings, the grantee has 25 days to respond and/or take corrective action.
  • In 2024, WIOA discretionary subrecipient monitoring occurred between February through June, but this schedule is subject to change.

Other helpful resources:

Full list of directives here, commonly used ones below:

  • WSD23-04 – WIOA 15 Percent Governor’s Discretionary Funds
  • WSD17-07 – WIOA Youth Program Requirements
  • WSD15-25 – WIOA Program Income