Greenville County Workforce Development Board …...Greenville County Workforce Development Board D....

Greenville County Workforce Development Board

D. Douglas Dorman, Chair

225 S. Pleasantburg Drive, Suite C11, Greenville, SC 29607

Tel 864‐797‐7909 Fax 864‐455‐5959

[email protected]

greenville.scworks.org

Greenville County Workforce Development Board (GCWDB) Meeting September 13, 2017

SC Works McAlister Square, Suite E1, Foothills Conference Room 11:30 a.m.

Agenda

I. Call to Order Mr. D. Douglas Dorman, Chair

II. Welcome and Introductions Mr. Dorman

III. Quorum Validation (9 or more) Mr. Dorman

IV. Minutes Approval (July 12, 2017)*

V. Director Report Mr. Dean E. Jones

1. WIOA Reports (Financial, Programmatic) 2. SC Works Certification Standards*

a. GCWDB Strategic Plan Update 3. WIOA Youth Budget – Unobligated funds for WIOA Out‐of‐School JAG Youth Program* 4. PY17‐18 Staffing Plans 5. Recap of the August 17, 2017 Joint Meeting of the GCWDB and UWB Executive

Committees: a. State Instruction 17‐01 b. SCDEW Regional Business Service Coordinators

6. SWDB SC Works Management Committee Participant Costs Policy Recommendation 7. Draft PY16 WIOA State Monitoring Report and GCWDB’s Draft Response 8. PY17 GCWDB CEO Agreement 9. PY17 GCWDB CEO Conflict of Interest Forms 10. PY17 GCWDB Conflict of Interest Forms

VI. Other Business

VII. Adjourn

* Denotes an action item.


July 12, 2017 1

Greenville County Workforce Development Board Meeting (GCWDB)

Wednesday, July 12, 2017 SC Works McAlister Square

225 S Pleasantburg Drive, Suite E1, Foothills Conference Room Greenville, SC 29607

MINUTES

Members Present: Doug Dorman (Chair), Robbie Dunaway, Kathleen Edwards, Ronny Gillespie Robyn Knox, Patrick Michaels, Michael Panasko, Kathy Stanton, John Tully (via conference), and Jermaine Whirl

Members Absent: Vernita Harris, Andrea Jannack, Shawn McCullough, Larry Pitts, David Turnipseed and Chuck Welch

Staff Present: Eva Anagnostis, Jay Blankenship, Elayne Gray, Shelia Harper and Dean Jones ResCare Workforce Services Staff: Rochelle Brown, Ruth McAninch, Stacey McKinney and Doug Stephenson Visitors: Amanda Lucas, SCDEW; Shannon Herman and John Hansley, Greenville County Government I. Call to Order: The meeting was called to order at 11:33 a.m.

II. Welcome & Introductions: Mr. Dorman (Chair) acknowledged visitors

III. Quorum Validation (9 or more): A quorum was validated

IV. *Minutes Approval (March 22, 2017 and May 10, 2017): Minutes of the previous meetings

were presented for approval. With there being no corrections noted, Mr. Dorman asked for a motion. It was moved to approve the March 22, 2017 and May 10, 2017 minutes. Motion was seconded without opposition, and carried. Minutes were approved as submitted respectively.

V. Director Reports: Mr. Dean E. Jones

1. Update on WIOA PY2017 Procurements:

a. SC Works Center Operator, Provider of WIOA Adult and Dislocated Worker Programs and Business Services (ResCare Workforce Services)

b. WIOA Youth (Goodwill Industries of the Upstate/Midlands, Inc.)


July 12, 2017 2

Both GCWDB PY 2017 WIOA Procurements were approved by Greenville County Council at its June 6, 2017 meeting.

2. PY 2017 WIOA Budget* ‐ This report was provided for information and included (but

was not limited to) the following: GCWDB WIOA Allotments for PY 2016 verses PY 2017, which included an increase of 1.24% compared to PY 2016

PY17 WIOA Administration Budget

PY17 WIOA Adult Program Budget

PY17 WIOA Dislocated Worker Program Budget

PY17 WIOA Youth Program Budget Questions, comments and concerns were addressed by Mr. Jones.

Staff submitted a recommendation for approval of the PY 2017 WIOA Budget. Before moving on, Mr. Dorman requested further clarification regarding the “Unobligated Funds of $162,523 for Youth Contract Modifications and/or Transition Activities.” Mr. Jones responded and provided more detail and specific information, with special mention of the JAG program. Further information will be addressed in the Director’s report per the agenda. Mr. Dorman stated the recommendation as proposed by staff to approve the PY 2017 WIOA Budget as submitted. It was so moved, seconded with no opposition and carried. Special note: Mr. Patrick Michaels, Goodwill Industries of the Upstate and Midlands abstained.

VI. Presentation ‐ ResCare Workforce Services: Ms. Rochelle Brown, Regional Director Mr. Doug Stephenson, Project Director

Ms. Brown provided some background information relative to her position as a Project Director for ResCare in the Upstate prior to moving into the Regional Director position. As the Regional Director, Ms. Brown serves operations across three states in the southeast. Additionally, Ms. Brown has ties to the Greenville area being that her mother is a native.

Mr. Stephenson shared that he is a retired veteran from the US Navy. After his retirement, he located to Florida, where he begin his career in workforce. After working in various fields for a number of years and subsequently visiting Greenville, Mr. Stephenson saw an opportunity in South Carolina. Mr. Stephenson now serves as the ResCare Project Director for the Greater Upstate region.


July 12, 2017 3

Ms. Brown and Mr. Stephenson presented the ResCare Workforce Services presentation via a handout and overhead projection. Some highlights from the presentation included, but were not limited to the following:

ResCare Incorporation is comprised of: Workforce Services, Home Care, Residential and Spring Health

About ResCare Where ResCare operate

Overview of Local Goals Transitions Status Functional Teams

Regional Workforce System(RWS) Greater Upstate – Local Leadership Team: ‐ Doug Stephenson, Project Director ‐ Pam Morris, Project Accountant ‐ Ruth McAninch, Comprehensive Center Manager, Greenville ‐ Deivis Henao, Comprehensive Center Manager, Spartanburg ‐ Johnnie‐Lynn Crosby, Regional Business Solutions Manager ‐ Nancy Wilson, Talent Development Supervisor Team Members consist of; 6 Talent Development Specialists, 2 Talent Engagement Specialist and 3 Business Services Consultants

Looking Ahead

Ms. Brown concluded with special thanks and recognition to Eva Anagnostis (GCWDB Special Projects) and Dana Wood (Associate Director, Upstate Workforce Board) for their help and support!

Mr. Jones also acknowledged ResCare Workforce Services for all their efforts during the

recent transition. Special thanks and acknowledgement to Mr. Joe Kernell, Greenville County Administrator, Mr. John Hansley, Deputy County Administrator, and the Workforce Development Board (WDB) for their continuous support.

3. Out of School JAG Program: Presented by Mr. Dean Jones

Brief highlights of the Out‐of‐ School JAG Program Application:

Provides the same elements of the traditional JAG In‐School Model

Enhanced support to meet the needs of the high school dropout, age 16‐24

Participants actively engaged for 6‐24 months prior to moving from active to follow‐up phase leading to employment

Follow‐up objectives to include: Job placement leading to a career; Postsecondary enrollment; Industry recognized credential; Postsecondary degree; Work‐based learning

Recommended contact hour average; 80 hours


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Opportunities would include; Workforce Innovation and Opportunities Act (WIOA); State Initiatives, to name a few

Mr. Jones explained the process by which the In‐School JAG program became obsolete. Jay Blankenship, Regional Workforce Advisor Greenville provided additional information relative to the former In‐School JAG program and the new Out‐of‐School JAG program. Mr. Jones assured the Board that discussions would continue with partners regarding the Out‐of‐School JAG program and additional information would be presented to them at a future meeting. 4. PY 2017 Business Services Lead Approval*: Ms. Eva Anagnostis

In reference to the SC Works Certification Business Services Standards, the Board’s attention was directed to the highlighted section on the handout. Ms. Anagnostis specified that according to the WIOA Certification Standards, the Business Services Team Lead is selected by the Local Workforce Development Board. Being in agreement with the Upstate Workforce Board, the staff recommendation is to select ResCare’s Regional Director of Business Solutions (Johnnie‐Lynn Crosby) as the Business Services Team Lead for the Upstate. Questions, comments and concerns were communicated and expressed, and as a result, a brief discussion took place. Ms. Anagnostis verbally provided a few examples of Ms. Crosby’s ability to lead the Business Services Team. Mr. Dorman requested a motion per staff’s recommendation. After considerable discussion and answered questions, the motion was seconded and carried.

5. Targeted Industries Policy*: Ms. Anagnostis Another staff recommendation as stated per Ms. Anagnostis, is relative to our targeted industries policies. After ample discussion, Mr. Dorman requested a motion to accept the staff recommendation and approve the Targeted Industries Policy as presented. It was moved, seconded and carried.

6. Proposed Amendments to the GCWDB Bylaws*: Ms. Anagnostis

In reference to the proposed amendments to the GCWDB Bylaws, staff once again directed the Boards’ attention to a recommendation to approve revisions to the GCWDB Bylaws. As reviewed in a previous Board meeting and in absence of several Board members, Ms. Anagnostis followed up by sending out the Bylaws via electronic mail. Therefore, Mr. Dorman appealed to the Board for a motion to approve staff recommendation for Proposed Amendments to the GCWDB Bylaws. Motion was seconded and approved by all in attendance. A subsequent email was sent to those not in attendance, and four members replied with an affirmative vote: Mr. McCullough, Mr. Pitts, Mr. Turnipseed, and Dr. Welch. With a total of 14 affirmative votes, there was


July 12, 2017 5

more than a two‐thirds majority. Motion to approve the amendments to the GCWDB Bylaws is carried.

7. Update on PY 2017 Election of Officers: Mr. Dean E. Jones

In regards to the Board’s membership, membership terms, and election of officers, Mr. Jones briefed the Board on the process by which a “Chair” must be elected. The Chair must be elected from the private business members on this Board. Therefore, Mr. Jones (with the approval of Mr. Dorman) solicited David Turnipseed, Chair of the Committee on Services to Individuals with Disabilities, to chair a nominations committee. Mr. Turnipseed is currently out of the office, but will be reaching out to the private business members at a later date.

8. PY16 WIOA Status Reports: Mr. Dean E. Jones A handout of the report was included in the package of information and reviewed in detail according to Mr. Jones to include: PY16 WIOA Financial Summary, July 1, 2016 – June 30, 2017

PY 16 WIOA Formula Allocation

PY16 WIOA Youth Contracts

PY15/PY16 Grants

VII. Other Business: None

VIII. Adjourned: Being there was no other business, the meeting was adjourned at 12:55 p.m.

* Denotes action item

Greenville County Workforce Development Board September 13, 2017, 11:30 a.m.

PY 2017 WIOA Financial Summary July 1, 2016 – August 31, 2017

PY16 WIOA FORMULA ALLOCATION

Allocation YTD Expenditure Expenditure Rate Balance

Adult Program $741,951 $685,757 92.43% $56,194

Adult Admin $82,437 $82,437 100% $0

DW Program $723,956 $723,956 100% $0

DW Admin $80,437 $80,437 100% $0

Youth Program $762,690 $762,690 100% $0

Youth Admin $84,743 $84,743 100% $0

PY17 WIOA FORMULA ALLOCATION

Allocation YTD Expenditure Expenditure Rate Balance

Adult Program $88,926 $0 0% $88,926

Adult Admin $9,880 $0 0% $9,880

DW Program $132,965 $0 0% $132,965

DW Admin $14,773 $0 0% $14,773

Youth Program $716,922 $634 .1% $716,288

Youth Admin $79,657 $1,771 2.22% $77,886

PY16 WIOA YOUTH CONTRACTS

Contractor Grant Amt. YTD Expenditure Expenditure Rate Balance

Goodwill Industries $547,503 $526,741 96.21% $20,762

PY15/PY16 GRANTS

Grant Grant Amt. YTD Expenditure Expenditure Rate Balance

PY15 Incentives $10,000 $1,898 18.98% $8,102

PY16 IWT $106,554 $57,166 53.65% $49,388

PY16 RR/IWT (RDG) $39,500 $0 0% $39,500

PY16 Regional Implementation $25,000 $0 0% $25,000

IWT = Incumbent Worker Training

RR/IWT = Rapid Response/Incumbent Worker Training

Training /Support Services Funding Adult ITA Funding 27132.63 Obligation Remaining 17050.58 Adult OJT 15,000.00 Adult OJT Obligated 0.00 Adult WEP Obligated 0.00 Adult Support Services 13,500.00 DW ITA Funding 15,000.00

Obligation Remaining 15,000.00

DW OJT 15,000.00 OJT Obligated 0.00 WEP Obligated 0.00 DW Support Services 16,500.00

Total AD/DW Obligated 13%

WIOA Orientation Attendees:(Group and One on One Sessions)

McAlister Square – 30

WorkKeys Completed: Greenville – 76

ASVAB Completed - 92

Greenville Just In Time Report

Ce nter J o b R e f e r r a l s

H i r e d

McA l i s t e r Square

2109 114

J . I .T . PY17

8/1/17 thru 8/31/17 Data

Business Services Focus - Greenville

4th – RDBS and BSCs met with TDS team to discuss benefits of OJT and develop a plan to coordinate efforts 7th – RDBS and PD met with local workforce boards regarding sector strategies and the business engagement plan and implementation timeline 15th – RDBS attended Greenville Chamber Workforce Summit planning meeting. The event is schedule to take place on October 12th and will focus on re-entry to include employer workshops, re-entry simulations and job fair. Details to come. 17th – RDBS presented to local and state board members regarding business services goals, metrics, best practices and challenges in the Greater Upstate region. 22nd – Business Solutions team members supported Chapin job fair hosted for those affected by VC Summer shutdown. Multiple Greater Upstate businesses participated. 23rd – RDBS met with SCDEW Area Director to go over and update business services standard operating procedures. Revised versions coming soon. 24th – SC Works Greater Upstate coordinated and attended CMC Apprenticeship information session

August Social Media Outreach: Facebook= Posts 30 and Likes 31

PY17 Goal‐ 250 New Likes

Twitter= 32 Posts and 6 New Followers PY17 Goal= 50 New Followers

August Community Engagement:

Goal: Greenville – 10 Actual: Greenville – 13

2 Highl ighted Events and Outreach

Program Year 2017 WIOA Enrollments/Training Goals: Greenville New Trainings ‐ 19

Adult Goal

Adult Actual

DW Goal

DW Actual

July 2 3 0 3

August 8 12 5 6

September 9 5

Q1Totals 19 15 10 9

PY 17 Goals 100 50

To reach 1st Q Goal +4 +1

Greenville Target Characteristics for PY 17 Enrollments ‐

PY17 Goals

PY 17 Actual

To Reach PY 17 Goals

Individuals with disability 18 1 17

Individuals with background 25 3 22

Veterans 25 4 23

M OU/ IFA negotiations are completed. Thank you to partners and

Board Staff who have worked so hard to come to an agreement.

The process for PY 17 should be finalized at the end of September.

The team participated in Rapid Response Activities with Fisher

Barton and Solvay.

o At Fisher Barton, staff assisted 75 workers with résumé

preparation.

o Recruitment events are scheduled at Fisher Barton for

September 6, 7 & 8th with 43 employers signed up.

The Team was blessed to observe the total solar eclipse on August

21. Thank you to our Leaders for allowing us to be a part of a “Once

in a lifetime” Experience.

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SC Works Management Standards

1. Partner integration is evident through non‐duplication of services and efficient and effective service delivery. The customer sees the Center as a single business unit.

2. The management structure is clear, as the roles and responsibilities of the partners at

the SC Works Centers as they relate to the management and governance of the center.

3. SC Works Centers have integrated staff development plans.

4. The SC Works Center is accountable for results.

5. Every SC Works Center is accessible so that all job seekers and business customers can fully participate in the services offered.

6. Every SC Works Center maintains a professional appearance.

7. Every SC Works Center has access to sufficient space and capacity for key functions.

8. Every SC Works Center is safe and secure.

SC Works Job Seeker Standards

1. SC Works Center measures satisfaction with both processes and outcomes for existing job seeker customers.

2. Feedback from job seekers is used to improve services.

3. SC Works Center will have a system in place to assess projected employer demand and

will align job seeker resources with current and projected employer demand.

4. Job Seekers will have multiple access points to SC Works services beyond the SC Works Center.

5. SC Works Center offers a consistent menu of job seeker services.

6. SC Works Center staff provides job seekers services they need as efficiently as possible

while maintaining a customer service focus.

7. SC Works Center will have well‐trained staff.

8. SC Works Center will have a well‐equipped resource room with trained staff to provide a broad range of job seeker services.

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9. All customers learn about the full range of services that are available through the SC Works System in a customer‐focused, program‐neutral way.

10. SC Works Center offers effective assessment and career guidance services to all job

seekers.

11. SC Works Center provides resources to assist customers with marketing themselves for employment.

12. Every SC Works Center will have information on as many jobs as possible.

13. SC Works Centers help job seekers advance their skills, education and occupational skill

attainment. SC Works Business Service Standards

1. There is a fully integrated multi‐agency business services team comprised of representatives from each of the federally mandated partners.

2. The Business Services Team is facilitated as a unified activity.

3. Businesses are consulted on their workforce needs.

4. The Business Services Team operates from a written LWDB business engagement plan

designed in response to business needs and that supports the vision of the SWDB.

5. There is a link between the activities of the Business Services Team, economic development and education entities.

6. Satisfaction with both processes and outcomes is measured for existing business

customers.

7. The workforce area offers a consistent menu of demand‐driven services. (See attached “Menu: SC Works Services to Business.”)

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Jones, Dean

From: Ferguson, Scott <[email protected]>Sent: Tuesday, August 29, 2017 8:58 AMTo: WIOA AdministratorsCc: Workforce SupportSubject: FW: Questions from the Administrator's Meeting

CAUTION: This email is from an EXTERNAL source. Ensure you trust this sender before clicking on any links or attachments.

Good morning! I apologize for the delay in getting this to you. Below are the responses to the questions you had regarding the Regional Business Service Coordinators.

‐ Who will they report to? Tiffany Jaspers, Business & Economic Development Manager

‐ What are their duties? The Coordinators will be expected to assist with rapid response coordination, data analysis, lead generation, large hiring events and other special projects where assistance is needed in the local area or region. Recognizing that individual areas may have different needs, their duties may vary by region.

‐ Do they talk to employers in the local areas? They will have minimal communication with employers (Rapid Response, large hiring events, as needed)

‐ What is their purpose/main function? Assist local areas with events, help coordinate efforts between all workforce partners in the region, coordinate regionally, assist local areas with projects and data analysis. These positions will assess needs and support the local BST teams, the intention is not to duplicate BST leads.

‐ How will they relate to the Integrated Business Service Team? Offering assistance and sharing information along with relevant data to Business Service Teams. They will attend Business Service meetings and organize regional team meetings. They will be available for on‐demand local Business Services assistance.

If you have any additional questions, please let me know. Thank you, R. Scott Ferguson Workforce Support Manager SC Department of Employment and Workforce 1550 Gadsden St. Columbia, SC 29202 P: 803‐737‐2671 TTY: dial 711

An Equal Opportunity Employer / Program Auxiliary aids and service available upon request to individuals with disabilities.

CONFIDENTIALITY: This email and any files transmitted with it contain information from the South Carolina Department of Employment and Workforce which may be confidential or privileged. The information is intended for business purposes only, and is to be used by the named recipients. If you are not the intended recipient, please be aware that any disclosure, copying, distribution or use of the contents of this message is prohibited. Please notify the sender immediately if you have received this email by mistake and delete this email from your system. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the South Carolina Department of Employment and Workforce.

Greenville County Workforce Development Dean E. Jones, Director 225 S. Pleasantburg Drive, Suite C11, Greenville, SC 29607 Tel 864‐467‐3620 Fax 864‐467‐3601 [email protected] greenville.scworks.org

August 11, 2017 Keri Dowd‐Pugh SCDEW Audit Director SC Department of Employment and Workforce P.O. Box 995, 1550 Gadsden Street Columbia, SC 29202 RE: Program Year 2016 WIOA Financial and Programmatic Monitoring Response – Greenville County Dear Ms. Dowd‐Pugh: Attached you will find Greenville County’s response to the WIOA financial and programmatic monitoring conducted by SCDEW from May 3, 2017 to May 4, 2017. A response has been provided to the monitoring issues/observations contained within the report. We appreciate the cooperation and assistance provided by the monitoring team. If you have any questions or require additional information, please contact me at (864) 467‐3605. Sincerely, Dean E. Jones, Director Greenville County Workforce Development Enclosure Cc: Doug Dorman, GCWIB Chairman Joe Kernell, County Administrator John Hansley, Deputy County Administrator Shannon Herman, Assistant County Administrator Angela Smith, WIOA Financial Operations

CURRENT YEAR ISSUES

1. Incen ve payments not in compliance with WIOA Regula ons During the on‐site monitoring review of participant files and Goodwill’s Youth Activities Contract, it was noted that Greenville County provided successful enrollment incentives as well as outreach and enrollment mentoring incentives to youth participants. The successful enrollment incentive payments were made to the participants beginning on the first day of WIOA participation. These incentives, as well as the outreach and enrollment mentoring incentives, were not related to achievements directly tied to training activities and work experiences. 20 CFR §681.640 states “Yes, incentive payments to youth participants are permitted for recognition and achievement directly tied to training activities and work experiences. The local program must have written policies and procedures in place governing the award of incentives and must ensure that such incentive payments are:

(a) Tied to the goals of the specific program; (b) Outlined in writing before the commencement of the program that may provide incentive payments; (c) Align with the local program's organizational policies; and (d) Are in accordance with the requirements contained in 2 CFR part 200.”

As of March 2017, Goodwill had expended $1,975 for costs associated with unallowable incentive payments to participants. Recommendation: We recommend that Greenville County update their incentive payment policies and procedures to ensure compliance with WIOA Regulations. We recommend that Greenville County staff review financial documentation and youth files to determine the total amount of disallowed costs associated with the noncompliant incentive payments, as well as provide proper incentive payment guidance to the frontline staff responsible for youth participant files. As of March 2017, Greenville County should submit a Corrective Action Plan (CAP) showing a repayment of $1,975 from Goodwill to Greenville County, including any subsequent expenditures, for noncompliant incentive payments from non‐WIOA funds. Additionally, Greenville County should outline steps taken to ensure costs incurred utilizing WIOA funds are allowable. Response: This finding was identified during local monitoring that took place on March 14 – 15, 2017. Greenville County notified Goodwill regarding the non‐compliant incentive payments on March 28 and subsequently provided technical assistance training to youth program staff. A final monitoring report was issued to Goodwill Industries on April 12, 2017 in which the report cited, in part, the non‐compliant incentive payments and disallowed the costs for the successful enrollments. Goodwill submitted several responses and/or communications to the monitoring with their first response dated on May 1, 2017.

SCDEW monitoring took place on May 3 – 4, 2017. SCDEW monitors were briefed on the Goodwill monitoring during the entrance meeting on May 3, 2017. A specific discussion was held regarding allowable youth incentives. Greenville County sent a follow up email to SCDEW on May 22, 2017 seeking clarification on the allowable WIOA youth incentive payments. On May 26, 2017, SCDEW responded with their decision regarding the incentive payment issue and that the Goodwill incentive payments for the successful enrollments are disallowed costs. As this unresolved issue was identified during the local monitoring process and ongoing technical assistance was being provided by Greenville County to Goodwill while awaiting final clarification from SCDEW, the appropriate Corrective Action Plan (CAP) steps were being taken, which were/are as follows:

Corrective Action Plan (CAP)

o On April 3, 2017, Goodwill/GRATIFY was issued their official PY ’16 Monitoring Report citing the “non‐compliant” Incentive Payments. See attachment #1

o On May 1, 2017, Goodwill/GRATIFY submitted their first monitoring response stating

that they would make arrangements to reimburse Greenville County in the time and manner prescribed/agreed. See attachment #2

o Verbal (telephone) conversations regarding the monitoring issues took place between

Greenville County and Goodwill over the next few weeks. During one telephone conversation, Goodwill communicated their disagreement with the decision to disallow the entire amount of incentive payments for the successful enrollments. Their (Goodwill’s) justification was that no guidance on the allowable incentive payment requirements was provided until approximately October/November 2016.

o On May 22, 2017, Greenville County sent a follow up email to SCDEW seeking for more

clarification regarding allowable Youth Incentive Payments.

o On May 26, 2017 SCDEW emailed clarification on incentive payments.

o On June 1, 2017 a subsequent monitoring letter was sent to Goodwill/GRATIFY

informing them that the Outreach & Enrollment Mentoring cost of $50.00 (fifty dollars and 00/100) and the Successful Enrollment cost of $1975.00 (one thousand nine hundred seventy‐five dollars and 00/100) are disallowed costs. See attachment #3

o Subsequently on June 7 2017, Goodwill Industries paid a prorated amount of $825.00

(eight hundred and twenty‐five dollars and 00/100) which reflects the disallowed cost amount for the successful enrollment incentive payments made after receiving guidance in October 2016 (at the Statewide Youth Coordinator Meeting).

o Greenville County accepted Goodwill’s final monitoring response and prorated

reimbursement as the lack of guidance more than likely contributed to the non‐

compliant incentive payments being made. However, Greenville County also acknowledges that some pertinent guidance was communicated at the October 2016 Statewide Youth Coordinator Meeting. Therefore, all non‐compliant incentive payments made after the October 2016 Statewide Youth Coordinator Meeting date would be disallowed costs. Goodwill Industries was also informed that a future State/Federal monitoring may require them to make full reimbursement back to the program for the successful enrollment incentive payments dating back to the start of PY16.

o On June 8, 2017, the Goodwill/GRATIFY’s executive staff was provided with information

and technical assistance during their PY17 WIOA Youth Contract Negotiations Meeting to ensure that the incentive payments are made in accordance to Department of Labor’s WIOA Federal Regulations §681.640.

o Effectively immediately, Greenville County’s WIOA Youth Program Incentive Policy is as

follows:

WIOA Youth Incentive Payments are permitted for recognition and achievement directly tied to training activities and work experiences. WIOA Youth Programs must submit written incentive payment policies and procedures to the Greenville County Workforce Development Board (GCWDB) for approval. Approved incentive policies are to be used to govern the award of incentives and must ensure that such incentive payments are: 1. Tied to the goals of the specific program; 2. Outlined in writing before the commencement of the program that may provide the

incentive payments. 3. Align with the local program’s organizational policies; and 4. Are in accordance with the requirements contained in 2 CFR part 200.

2. WIOA paid for non‐WIOA expenditure

We noted that Greenville County utilized WIOA funds to pay for non‐WIOA related costs totaling $380.10. The expenditures were for an IPad’s monthly data plan beginning 5/1/16. The WIOA Administrator had two IPads and was incurring costs for two data plans for those IPads. This cost is duplicative and not considered necessary and reasonable for the proper administration of the program. 2 CFR 200.403 (a) states, “Costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.” 2 CFR 200.405 (a) states, “A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.” Recommendation: We recommend that Greenville County ensure that transactions charged to the WIOA program are reasonable, necessary, and allocable. Greenville County should submit a CAP showing a repayment of $380.10, including any subsequent expenditures for related costs, from non‐WIOA funds. Additionally, the CAP should indicate actions taken to ensure only

necessary, reasonable, and allocable costs are charged to the WIOA program.

Response: The below issue was discussed during the monitoring. The Director has two IPads, IPad #1 was the first purchased in 2012. This IPad has many WIOA documents and thousands of WIOA electronic communications stored on it. As IPad #1 was reaching its maximum storage capacity, IPad #2 was purchased a few years later. SCDEW monitors questioned the need for 2 IPads during the monitoring and it was communicated that IPad #1 is primarily being used as a backup one to store old files, documents, and emails. As information stored on IPad #1 is needed, I email it to myself. Also and more importantly, IPad #1 contains a large amount of WIA information that may have been pertinent to an ongoing WIOA personnel matter. It is for both of these reasons that the Director primarily maintained cellular service on IPad #1. Greenville County acknowledges that costs must meet general criteria such as being necessary and reasonable for the performance of the Federal award and that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. We strive to adhere to all rules and regulations pertaining to cost principles. However, Greenville County disagrees with this monitoring finding and recommendation. Greenville County asserts that under the circumstances, the Director’s decision to continue maintaining an active cellular subscription on IPad #1 is reasonable and allowable cost, and related to the performance of duties. Greenville County is requesting SCDEW’s reconsideration on this finding by determining that the costs ($380.10) related to this finding is allowable. NOTE: Since the monitoring in May 2017, the Director is accessing needed documents from IPad #1 by a wireless network. Additionally, the WIOA personnel matter(s) have been resolved and the Director has cancelled the monthly cellular subscription for IPad #1. This finding will not be an issue at a future monitoring. Corrective Action Plan (CAP) To ensure that electronic data equipment, software, and other tools that may require a monthly/annual subscription cost are cancelled in a timely manner once no longer is use or determined to be essential to operations, the below Corrective Action Plan (CAP) will be adhered to: o Greenville County will conduct an annual inventory of all electronic equipment during

internal monitoring during each program year. o Greenville County will conduct an annual audit of all subscription services during internal

monitoring during each program year. o During each program year, Greenville County will dispose of all obsolete equipment after

purging/transferring records/information to storage and will cancel the subscriptions for such equipment (including software) if it is determined at that time to be non‐essential to the WIOA program operations.

o All deficiencies are noted within the internal/local monitoring reports. Copies of internal monitoring reports are forwarded to SCDEW.

3. WIOA personnel costs were allocated based on budgeted es mates THIS IS A REPEAT ISSUE In prior year, Greenville County allocated personnel costs based on budget estimates. During our current on‐site monitoring, we noted that Greenville County continues to allocate personnel costs based on budgeted estimates. Greenville County staff actual work hours are expected to match budgeted work hours. Per Greenville County, any significant deviations in actual work hours from the budgeted hours assigned should be reviewed leading to adjustments in budgeted hours or work duties. The expectation is that staff would actually work the budgeted hours assigned. Per our review, the timesheets reflect budgeted patterns with no indications of adjustments made for actual workloads outside of leave taken. Allocation of personnel costs should be based on actual time worked on a program and not pre‐determined budget estimates. This allocation methodology has the potential to distort the final results because it is not based on actual effort or actual expenditures.

2 CFR §200.430 (i)(1)(viii) states, “Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:

(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non‐Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non‐Federal entity's system of internal controls includes processes to review after‐the‐fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.”

Recommendation: We recommend that Greenville County develop and utilize an acceptable allocation methodology to allocate personnel costs which reflects the actual activity benefiting from the work completed instead of budget estimates. Greenville County should provide a CAP that will outline steps taken to ensure applicable costs are allocated based on actual time benefiting the final cost objective. Response: As discussed during the last two monitoring visits, Greenville County has provided in‐house services for years. Under the WIA and WIOA, Greenville County has performed duties of the One‐Stop Operator and WIOA Adult and Dislocated Worker Program and Business Services. It was more cost effective to split some staff time between performing board duties versus One‐Stop Center/WIA/WIOA duties. In order to simplify the time allocation process, internal time sheets were created during PY15 and a new time allocation guide was developed during PY16 to help staff manage the amount of time (and allocation of costs) being spent devoted towards

performing Board duties versus and Operator duties. Corrective Action Plan (CAP) Effective July 1, 2017, Greenville County has a straightforward process to ensure applicable costs are benefiting the final cost objective, which is to carry out the duties of the Workforce Development Board per the Statement of Work. All Workforce Development personnel costs are allocated based on actual time spent providing Statement of Work activities for the Board and WIOA Program. Greenville County is no longer performing the duties of the One‐Stop Operator and there is no longer a need to allocate time Board time and/or One‐Stop Operations time. The next annual SCDEW monitoring will reflect our new budgeting and time allocation process as well as any other related improvements made since the PY16 monitoring.

OPPORTUNITY FOR IMPROVEMENT The following observation is not an issue, but rather an opportunity for improvement. Therefore, we recommend Greenville County review this comment for future improvements.

1. High “Other Staff and Opera ng Costs” for Adult and DW funds

Based on expenditures incurred in PY16 through May 2017, Greenville County has incurred a high percentage of costs in the “Other Staff and Operating Costs” category. This category includes the following line items: Salaries/Fringe Benefits, Operating Expenses, Indirect Costs, and Other.

As noted in the above chart, Greenville County reported spending 17.1% and 13.2% of WIOA funds on Adult and DW participants for training related purposes, respectively. Additionally, we noted that a very large percentage of Youth expenditures is reported as “Staff Working Directly with Participants”. Recommendation: We recommend that Greenville County assess its current expenditure composition to ensure the “Training and related expenses” category receives priority when incurring WIOA costs. We welcome any comments from Greenville County to provide further clarification surrounding the above noted recommendation. Response: The next annual SCDEW monitoring will reflect the improvements made regarding the Other Staff and Operating Costs for Adults and Dislocated Workers over the past year and since completing the competitive procurement of an Operator. Greenville County continues to pay for the SC Works Center costs on behalf of the Infrastructure Funding Agreement (IFA) partners until such time as those funds are reimbursed. Currently, it takes approximately 3 – 4 months for to receive our IFA reimbursements. Greenville County would like to see an improvement in the process for receiving IFA reimbursements so that reimbursements are made in a more timely fashion.

Programmatic Monitoring Review WIOA Programs

Purpose and Scope The purpose of the programmatic review was to ensure that the Greenville County programs were compliant with applicable statutes, regulations, and guidelines. The scope of the review included the following areas:

1. Governance 2. SC Works Delivery System 3. SC Works Online System 4. Adult, Dislocated Worker, and Youth Program Activities 5. Service Provider Review 6. Participant File Management

The programmatic monitoring of PY’16 WIOA activities was accomplished through documentation review, observation of operation, data testing, and interviews with WIOA staff. WIOA monitors traveled to the Greenville SC Works center and Goodwill Job Connection. Greenville County and sub‐recipient staff were interviewed during the course of the monitoring visit.

CURRENT YEAR ISSUES

1. Personally Iden fiable Informa on (PII) in par cipant file

THIS IS A REPEAT ISSUE

A Full Social Security Number (SSN) was identified on a college transcript form in the following participant file: State Identification # 3229309. This item is considered PII and should not be displayed in the participant file. The USDOL characterizes “Protected PII” in TEGL 39‐11 as follows:

PII, which when disclosed, could result in harm to the individual whose name or identity is linked to that information. This is distinguished from “Non‐sensitive PII,” the disclosure of which cannot reasonably be expected to result in personal harm. Protected PII includes, but is not limited to: Social Security number, credit card number, bank account number, residential address, residential or personal telephone number, biometric identifier (image, fingerprint, iris, etc.), date of birth, place of birth, Mother’s maiden name, criminal records, medical records, and financial records.

State Instruction Letter 08‐05 states, “The full social security number should not be required on any locally‐developed form. If necessary, no more than the last (4) digits may be used. All locally‐developed forms should be reviewed and revised accordingly. Active participant files should be reviewed. If the full social security number is visible on such forms, staff should cover at least the first five digits of the number with a permanent marker.” Recommendation: Participants are required to submit PII documentation for various reasons. It

is crucial that the required documentation for the participant hard file be reviewed for Protected PII. Unnecessary information found on any submitted documents or forms should be modified immediately. We recommend that Greenville County staff review active files for such sensitive information, as well as provide guidance to the frontline staff responsible for participant file creation. Greenville County should provide a CAP that will outline steps taken to ensure PII is redacted in a timely manner. Response: Greenville County takes a very serious view when it comes to safeguarding Personally Identifiable Information (PII). However, we also acknowledge that human error occurs no matter how hard you strive to protect confidential information. Our Corrective Action Plan is: o PY17 WIOA contractors and case managers will be required to conduct an audit of

participants’ files once per quarter to ensure that all PII information has been properly safeguarded.

o During annual (PY17) monitoring, monitoring staff will audit 100 percent of the participant files to determine whether or not PII compliance is being maintained.

o All deficiencies will be noted within the internal/local monitoring reports and the deficiencies pertaining to PII compliance will be immediately rectified.

o Copies of all internal/local monitoring reports will be forwarded to SCDEW.

2. Veterans’ Priority Signage was not displayed Veterans and other covered persons are entitled to a priority of service under all WIOA Title I funded programs. Every Local Workforce Development Area (LWDA) is required to have a written policy to ensure veterans and covered persons receive priority services. During the on‐site monitoring, it was noted that signage was not displayed at one location to inform veterans of this priority. Per Training and Employment Guidance Letter (TEGL) 10‐09 issued by USDOL, “The policy or policies must require that processes are in place to ensure that veterans and eligible spouses are identified at the point of entry and given an opportunity to take full advantage of priority of service.” The TEGL further indicates, “Written copies of local priority of service policies should be maintained at all service delivery points and, to the extent practicable, should be posted in a way that makes it possible for members of the general public to easily access them.” Recommendation: We recommend that Greenville County visibly display veterans’ priority signage at the point of entry of each service provider to ensure veterans and the general public is made aware of the policy. Greenville County should submit a CAP outlining steps taken to ensure veterans’ signage is maintained in an easily viewable area. Response: The veterans priority signage apparently was moved from its original location at the point of entry.

Corrective Action Plan (CAP)

o The Veterans Priority Signage will be posted conspicuously within the point of entry and several signage posters will be placed at the resource room help desk, another sign to be placed within the case manager offices/suites, and finally a scrolling message on Veterans Priority will constantly be displayed on the resource room electronic monitors.

Opportuni es for Improvement

The following observations are not issues, but rather opportunities for improvement. Therefore, we recommend Greenville County review these comments for future improvements.

1. Low par cipa on rates in Adult, DW, and Youth customer groups As of July 18, 2017, Greenville County has low participation rates in the Adult, DW, and Youth customer groups for PY’16. Greenville County has seen a steady decline in Adult and DW participation since PY’13. In contrast, Greenville County’s Youth participation has slightly increased since PY’13 until this program year. At the current participation rates, Greenville County will fail to meet prior year participation rates in the Adult, DW, and Youth customer groups at the end of the program year. Recommendation: We recommend Greenville County assess the Adult, DW, and Youth participation rates to determine the reasoning behind the decline in activity. Additionally, we recommend Greenville County bolster their outreach and service delivery models to reach hard to serve segments of the Adult, DW, and Youth customer groups. We welcome any comments from Greenville County to provide further clarification surrounding the above noted recommendation. Comment: Grenville County has assessed that the One‐Stop Operator procurement requirement had an impact on our ability to maintain a push to recruit new participants. PY17 should be a better year for increasing recruitments as the transition is now over. The mandated 70 percent Adult Program Priority of Service requirement is impacting our ability to serve more under‐employed workers. Greenville County has one of the lowest unemployment rates, with our June UI rate at 3.7%. However, the State requires our region to serve the same percentage (70%) of low income adults as more distressed areas. Bamberg County’s UI rate for June 2017 was 7.6%. Greenville County’s UI rate for June 2017 was 3.7. Greenville County would like for flexibility to set its own priority of service level so that it aligns with the Greater Upstate Region’s labor market conditions.

2. No Open 414 or 433 Ac vity Codes

The definition for the Ad Hoc Report titled Youth ‐ LitNum ‐No Open 414/433 is as follows: “Lists the active out‐of‐school youth participants who are Basic Skills Deficient (based on latest test results), but are not currently enrolled in Activity Code 414 (Basic Skills Training) or Activity Code 433 (GED Training or Adult Ed High School). These individuals will count negatively in the Literacy/Numeracy measure.”

A review of this Ad Hoc report on July 18, 2017 for PY’16 indicated that 37 basic skills deficient active Youth participants’ needs are not being addressed by either basic skills or GED training. By entering other services before addressing the participant’s basic skills deficiency, the Local Workforce Development Area (LWDA) has not provided the foundation the participant will need to be successful going forward. There may be activities/services that Youth can access, but their ability to move beyond the initial stages of these activities may be severely hampered by the lack of basic skills. Recommendation: We recommend that Greenville County improve youth basic skills deficiencies to ensure participants overall success in the workforce. Greenville County should work to address potential Youth participant barriers through comprehensive assessments and the development of individual service strategies. Below is a list of techniques/activities that have been used by other LWDAs in SC to help Youth achieve basic skills competency:

Limit Occupational Skills Training to those who are no longer basic skills deficient.

Have hesitant Youth commit to shorter goals to ensure engagement then revisit 413/433 activity.

Use other assessment tools to support Basic Skills remediation (ex. WorkKeys, career – smart classes).

Maximize incentives available for remediation and basic skills competencies.

Track when a participant’s basic skills are due to be retested.

Record all pre‐test and post‐test scores in SCWOS.

We welcome any comments from Greenville County to provide further clarification surrounding the above noted recommendation. Comment: Greenville County appreciates the recommendations for improving remedial activities for youth. Greenville County is working with the youth service providers to ensure that participant needs are being addressed by either basis skills or GED training, as appropriate and according to their career and training plan.

3. Low par cipa on in On‐the‐Job Training (OJT)

As of July 18, 2017, Greenville County had entered into two (2) OJT agreements for PY’16. As of July 18, 2017, the state average number of OJTs per LWDA in PY16 is roughly 36 OJTs. Greenville County’s previous OJT numbers vary from 30 in PY’14 to 2 in PY’15 and PY’16. Per Greenville County, there was a transition in business service responsibilities during the PY’16 program year.

OJT’s are mutually beneficial for employers and participants. It offsets the high costs of training a new employee and the associated loss of productivity for a business. In addition, participants gain valuable skills while earning wages, likely resulting in full‐time, self‐sustaining employment. The lack of OJT participation in the area limits participant choice and impacts service delivery. Recommendation: We recommend that case managers and business services staff work together in Greenville County to promote OJT opportunities to better assist businesses and

participants. There are helpful resources to aid in planning and implementing an effective OJT program. We encourage Greenville County to provide business services staff with training modules, template documents, and effective marking strategies that can be found at https://ojttoolkit.workforce3one.org/. We welcome any comments from Greenville County to provide further clarification surrounding the above noted recommendation.

Comment: Greenville County successfully completed a major transition to a competitively procured service delivery system and projects there will be some lag in PY17 startup activity. However, we do anticipate ongoing improvements will be made regarding the number of 414 and 433 activity codes to be opened.

Issue #1: Greenville County is not enrolling new participants Greenville County is not enrolling any new participants into the WIOA program for PY' 15. Per discussion with Greenville County personnel, enrollment into all funding streams for PY' 15 was ceased and not anticipated to continue till August due to questions arisen as the result of the transition from the WIA to the WIOA. Providing eligibility and "wait‐listing" eligible participants will create a backlog and deny timely services to eligible participants. In accordance with WIOA § 134(c}, funds allocated to a local area for Adults and DWs shall be used to provide a one‐stop delivery system, career services, training services, develop relationships and networks with employers, and establish partnerships with industry or sector partners. Recommendation: We recommend that Greenville County utilize every opportunity for outreach in order to attract and serve those individuals in need of WIOA services. Every effort needs to be undertaken to ensure the availability of services to those in need in a timely manner. Additionally, we recommend that Greenville County request technical assistance regarding questions arisen as the result of the transition from WIA to WIOA. Technical assistance is available upon request.

Response: Greenville County successfully completed a major transition to a competitively procured service delivery system and projects there will be some lag in PY17 startup activity. However, we do anticipate ongoing improvements will be made regarding new participant enrollments.

CLEO/WDB Agreement – 7/1/2017 1

GREENVILLE COUNTY CHIEF LOCAL ELECTED OFFICIAL (CLEO) WORKFORCE DEVELOPMENT BOARD (WDB)

AGREEMENT The Greenville County Workforce Development Board (WDB) and Greenville County chief local elected official (CLEO) established a partnership for the operation of the Workforce Innovation and Opportunity Act (WIOA) of 2014 (PL 113‐128). By signing, the CLEO/WDB agreement shall remain in force until amended in writing by the mutual consent of both parties listed above. SECTION 1 – CHIEF LOCAL ELECTED OFFICIAL (CLEO) The chief local elected official (CLEO) shall serve as the local grant recipient for, and shall be liable for any misuse of, the grant funds allocated to the local area under Sections 128 and 133, unless the chief elected official reaches an agreement with the Governor for the Governor to act as the local grant recipient and bear such liability. The CLEO also has the responsibility to appoint members to the local Workforce Development Board (WDB) and to remove board members if determined to be in the best interest of the WDB to do so. The Workforce Innovation and Opportunity Act (WIOA) implies that such standards for removing board members derive from the authority to appoint them. SECTION 2 ‐ DESIGNATION OF THE GRANT RECIPIENT Per Section 107 of the Act, the CLEO in the local area shall serve as the grant recipient. The chief local elected official has designated County of Greenville to be the WIOA grant recipient. This designation, however, does not relieve the CLEO of the liability for any misuse of grant funds under Section 128 and 133. SECTION 3 ‐ DESIGNATION OF THE ADMINISTRATIVE ENTITY Per Section 107(f) of the Act, the local board may hire a director and other staff to assist in carrying out the functions described in subsection (d) using funds available under sections 128(b) and 133(b) as described in section 128(b)(4). Greenville County Workforce Development Office board staff is designated as the entity to assist the WDB and CLEO with administration and program oversight for the local WIOA programs of youth activities authorized under Section 129, local employment and training activities authorized under Section 134, and the local One‐Stop delivery system in the local area pursuant to the WIOA and consistent with the local WIOA plan. SECTION 4 ‐ DESIGNATION OF THE ONE STOP OPERATOR The local WDB, with the agreement of the CLEO, shall procure the one‐stop operator through a competitive process; the one‐stop operator shall be an entity (public, private, or nonprofit), or consortium of entities [including a consortium of entities that, at a minimum, includes 3 or more of the one‐stop partners described in subsection (b)(1)], with demonstrated effectiveness, located in


the local area. SECTION 5 ‐ DEVELOPMENT OF A LOCAL STRATEGIC PLAN The Greenville County WDB shall develop and submit to the Governor a comprehensive local 4‐year plan, in partnership with the CLEO. The local plan shall support the strategy described in the State plan in accordance with Section 102(b)(1)(E), and otherwise be consistent with the State plan. SECTION 6 ‐ FUNCTIONS AND RESPONSIBILITIES Pursuant to Section 107(d), the Greenville County Workforce Development Board will be responsible for the following: 1. Development of the local plan;

2. Workforce research and regional labor market analysis;

3. Convening, brokering, leveraging in order to leverage support for workforce development

activities;

4. Employer engagement;

5. Career pathways development;

6. Proven and promising practices;

7. Technology strategies that will enable maximum accessibility and effectiveness;

8. Program oversight for activities authorized under Section 129(c), local Sections (c) and (d) of Section 134, and the local one‐stop delivery system;

9. Negotiation of local performance accountability measures;

10. Selection of one‐stop operators consistent with Sections 121(d) and 123;

11. Coordination with education providers; 12. Budget and Administration; 13. Accessibility for Individuals with Disabilities. SECTION 7 – FISCAL AGENT The County of Greenville, as the designated fiscal agent, shall be responsible for the following per Section 107(d):


1. Receiving and maintaining the grant funds; 2. As applicable, contracting for programs or services, soliciting proposals or bids, selecting

reputable contractors, and executing contracts that contain standards for ensuring accountability, clear performance goals, and standards for contractors;

3. Providing financial services for the WDB in the same manner and to the same extent as the

services provided to WIOA contractors as administered by the Workforce Development Office;

4. Providing personnel and purchasing services to the WDB in the same manner and to the

extent accorded to other operating entities under provisions of existing Greenville County Personnel and Purchasing Regulations; and

5. Conducting audits and other financial examinations where deemed necessary. SECTION 8 – BOARD STAFF Section 107(f) grants local board staff, as the Administrative Entity (Workforce Development Office), to be responsible for the following:

1. The disbursal of funds; 2. Taking action against its subcontractors, subgrantees, one‐stop operators, eligible providers

of training services, and other subrecipients to eliminate abuses in the program;

3. Preventing any misuse of funds by subrecipients;

4. Providing administrative/managerial support to the WDB and its standing committees in carrying out its responsibilities as prescribed in Section 9 of this agreement and the Act;

5. Provide oversight and general direction to One‐Stop Operators in their roles as operators;

6. Assisting the CLEO, WDB and Youth Committee with establishing contract specifications and

procedures for soliciting bids/proposals;

7. Submit contracts and memorandums of understanding (MOUs) to the CLEO for approval;

8. Providing contract supervision and technical assistance to contractors;

9. Establishing and maintaining a management information system;

10. Preparing program and financial status reports for scheduled WDB and Youth Committee meetings and upon request;

11. Assist the WDB with preparation of the local 4‐year plan; and


12. Provide oversight of WIOA program operations, services and activities.

SECTION 9 ‐ ADMINISTRATIVE STRUCTURE

The Greenville County Workforce Development Area will maintain the following structure:

SECTION 10 – ROLE OF ONE‐STOP OPERATOR Per Section 121(e)(1) of the Act, a one‐stop delivery system shall:

1. Provide the career services described in section 134(c)(2);

2. Provide access to training services as described in section 134(c)(3), including serving as the point of access to training services for participants in accordance with sections 134(c)(3)(G);

3. Provide access to the employment and training activities carried out under section 134(d), if any;

4. Provide access to programs and activities carried out by one‐stop partners described in subsection (b); and

5. Provide access to the data, information, and analysis described in section 15(a) of the Wagner‐Peyser Act (29 U.S.C. 491‐2(a)) and all job search, placement, recruitment, and other labor exchange services authorized under the Wagner‐Peyser Act (29 U.S.C. 49 et


seq.) In witness whereof, the parties have executed this agreement:

CHIEF LOCAL ELECTED OFFICIAL __________________________________________ ______________________ Herman G. “Butch” Kirven, Jr., County Council Chairman Date __________________________________________ ______________________ Joseph Kernell, County Administrator Date WORKFORCE DEVELOPMENT BOARD __________________________________________ ______________________ D. Douglas Dorman, WDB Chairman Date

Greenville County Workforce Development Board (WDB) Chief Local Elected Official

Conflict of Interest Attestation Form Instructions Chief Local Elected Officials shall not appoint an individual to serve on the Greenville County WDB if he or she has an ownership interest or is employed by an organization that receives money under the direct control of the board, or if the individual engages in any other activity that creates a conflict of interest or what would appear to be a reasonable person to be a conflict of interest. Exception – An individual who has an interest in or is employed by an entity that receives money under the partial or complete control of the Greenville County WDB may be appointed to, or continue to serve, on the board if the individual does not hold a policymaking position with the entity and would not receive other than a remote or incidental benefit from the board’s decisions. The exception applies to allow local WDB representation from entities such as a school that enrolls students with tuition paid from funds under the control of the board, a government agency from which representatives is required, and an employer that accepts compensation for the extraordinary costs of providing employer‐based training from funds under the board’s control. The Conflict of Interest Attestation Form must be signed by the Chief Local Elected Official and submitted to the Workforce Development Office to be maintained for board certification purposes. This form is an attestation that a conflict of interest does not exist in regard to all Greenville County WDB members.

GREENVILLE COUNTY WORKFORCE DEVELOPMENT BOARD (WDB)

CHIEF LOCAL ELECTED OFFICIAL (CLEO) CONFLICT OF INTEREST ATTESTATION FORM

Program Year: 2017 I, the undersigned, do attest that a conflict of interest does not exist with any of the Greenville County WDB members. Joseph Kernell_______________________________ County Administrator’s Name (typed) ___________________________________________ County Administrator’s Signature _______________________ Date Herman G. “Butch” Kirven, Jr._______________________________ Chief Elected Official’s Name (typed) ___________________________________________ Chief Elected Official’s Signature _______________________ Date

Please provide the signed copy to:

Greenville County Workforce Development 225 S. Pleasantburg Drive, Suite C11

Greenville, SC 29607 Email: [email protected]

Greenville County Workforce Development Board (WDB) Member Conflict of Interest Attestation Form Instructions

Greenville County WDB members ensure that their individual interests do not conflict or interfere with their duties while serving in their appointed positions. Conflict of interest requirements must be met as soon as board members are appointed. A conflict of interest is a circumstance in which the Greenville County WDB member’s individual interest impairs (or gives the appearance of impairing) their ability to make unbiased decisions or provide unbiased public services. The Greenville County WDB membership must adhere to both federal and state conflict of interest requirements. All appointed Greenville County WDB members must complete and sign the Conflict of Interest Attestation Form annually (PY) and the signed forms must be submitted and maintained by the Greenville County Workforce Development Office for board certification and monitoring purposes.

GREENVILLE COUNTY WORKFORCE DEVELOPMENT BOARD (WDB) CONFLICT OF INTEREST ATTESTATION FORM

Program Year: 2017 I, the undersigned, do attest that a conflict of interest does not exist with my individual interest as: _____________________________________ _____________________________________________ (Job position) (Company/Agency Name) And my ability to make unbiased decisions while serving as a member of the Greenville County WDB. ___________________________________________ Greenville County WDB Member’s Name (printed) ___________________________________________ Greenville County WDB Member’s Signature _______________________ Date

Please provide the signed copy to:

Greenville County Workforce Development 225 S. Pleasantburg Drive, Suite C11

Greenville, SC 29607 Email: [email protected]

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