Michigan

State agencies are required to include specific information in the grant award notifications issued to AEFLA subrecipients.  MILEO provided each AEFLA subrecipient with a letter of an award notification and the contract, which included the terms and conditions of receiving federal funds.  However, MILEO did not include all elements required by the Uniform Guidance.  Specifically, the award letter and contract did not include the Federal awarding agency and the federal award identification number.

MILEO must issue corrected subaward documents to all subrecipients no later than the end of the current continuation award period, to include all of the required information listed in the Uniform Guidance.

WIOA requires that whenever a State adds a requirement based on a State rule or policy that is not imposed under federal law or regulation, it must identify the rule or policy as being imposed by the State.

For the PY 2020 competition, MILEO included several State-specific requirements in the grant application materials and identified them as such.  However, there were instances in which MILEO did not correctly apply the requirement.  For example, MILEO prioritized applicants with strong collaborative partnerships and those with effective strategies to deal with diverse populations.  These priorities were not clearly identified as State priorities.  In addition, MILEO did not clearly identify the absolute restriction against using any grant funds for workforce training as a State requirement.

MILEO must revise its application materials to clearly and consistently identify requirements that are based on the State’s rules or policies.

AEFLA requires eligible providers to include in their local applications information and assurances that describe how they will fulfill their one-stop partner responsibilities, which may include: providing access to adult education and literacy through the one-stop delivery system; using funds available under WIOA to maintain the one-stop delivery system; entering into memoranda of understanding (MOUs) for operating one-stops with local workforce boards; participating in the operations of the one-stops, consistent with the MOUs; and providing representation to the State board.

MILEO delegated all one-stop responsibilities to all AEFLA-funded local providers.  However, local providers were not asked to provide information in their applications addressing the delegated responsibilities.

MILEO must ensure that local providers with delegated responsibilities for the one-stops include the description of how they plan to address all five responsibilities in their applications, as appropriate.

States inform potential applicants, WIOA partners, and the public about their AEFLA programs and the activities they intend to support in their State Plans, which are due every four years and modified after two years.  In addition, a State identifies the activities it will fund through the local competition process in its application materials.

MILEO did not include the Integrated English Language and Civics Education (IELCE) activity as an allowable activity funded through the section 231 basic grant in its 2020 State Plan, 2022 modification, or the 2020 local application materials.  Discussions with State staff confirmed these activities were funded in the 2020 AEFLA competition.

MILEO must include IELCE as an activity in its 2024 State Plan and its 2024 local AEFLA competition application materials, if it intends to allow applicants to implement IELCE as an activity under section 231.

States may include family literacy activities as allowable activities for local competitions.  In providing family literacy activities under title II, an eligible provider shall attempt to coordinate with programs and services that are not assisted under title II prior to using funds for adult education and literacy activities under this title for activities other than activities for eligible individuals.  Title II also requires four integrated activities for family literacy, one of which is an age-appropriate education to prepare children for success in school and life experiences.

In its application materials, MILEO stated that Michigan regulations require family literacy funds be used for the education of the parents, only.  This requirement does not comply with AEFLA and must be revised.  Discussions with State staff and a review of NRS Table 8 confirm that family literacy services are offered in Michigan.

MILEO can either remove family literacy as a permissible activity or it must revise its requirements for implementation to align with WIOA.  MILEO must inform currently funded providers of the changes and update the applications for the PY 2024 AEFLA competition.

States are required to monitor the activities of subrecipients to ensure that the subawards are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.  This includes monitoring data quality, performance, financial management, and all aspects of program implementation.  Monitoring also includes following-up and ensuring that the subrecipients take timely and appropriate actions on all deficiencies pertaining to the federal award.  Finally, monitoring includes documentation of the status of actions planned or taken to address findings related to the particular subawards.

Based on the review of documents and discussions with State office staff, the review team determined that MILEO is not adequately addressing the monitoring requirement.  MILEO conducts regular desk monitoring, which includes reviewing data for annual reporting into the National Reporting System (NRS), performance narrative reports, and expenditure reports.  However, MILEO has not conducted in-depth monitoring in at least five years of performance and enrollment data management, financial management, program implementation, and performance of one-stop delegated activities.  For this monitoring review, MILEO submitted a single monitoring report from 2018, with no evidence of follow up and closure of corrective actions.

Michigan has the second highest number of local providers in the country.  This requires substantial staff and financial resources to monitor effectively and regularly.  The local providers are not being monitored for compliance with the federal requirements applicable to AEFLA.

MILEO must develop a process, procedures, and tools, for a monitoring plan that is adequate to ensure subrecipient compliance with all applicable grant requirements.  This plan should also include a plan to regularly monitor each subrecipient.  These policies and procedures must include investigating subrecipient practices, reviewing audits and agreed-upon procedures, reporting each monitoring review and any deficiencies identified, ensuring subrecipients take timely and appropriate actions to correct deficiencies, and closing out any corrective action.