Sorry, you need to enable JavaScript to visit this website.
Skip to main content
U.S. flag

An official website of the United States government

Oregon

State Abbreviation
OR
Area
Region
State Flag
Oregon Flag
State Capital
Salem

Finding

Module
Module 2 - Fiscal
Finding

HECC did not report non-federal matching and Maintenance of Effort (MOE) expenditures in accordance with the requirements in WIOA.

Discussion

States are required to provide, from non-federal sources, 25% of the total amount of funds expended for adult education and literacy activities in the State in order to meet the section 222 match requirement under WIOA.  According to the Uniform Guidance, matching has several requirements, including being necessary and reasonable for accomplishment of program objectives and not being used as a contribution for other federal awards.  In addition, WIOA and the Uniform Guidance have requirements for allowable expenditures and activities.  Finally, the Uniform Guidance requires written procedures for managing federal grant and matching funds, including procedures to determine the allowability of costs.

In a review of the State’s PY 2019 and 2020 FFRs, HECC reported 85.71% and 87.11% match, respectively, which the State indicated came from local funds.  HECC indicated that in addition to the Oregon Adult Basic Skills Title II Adult Education and Literacy Grant Policy Manual, HECC provided extensive training to local programs to ensure the programs were adhering to match requirements and also conducted monitoring for risk assessment and program improvement of selected local programs, in which fiscal monitoring periodically took place.  However, in document reviews and interviews with State staff, the federal review team was unable to determine that HECC could verify that the matching funds reported by local providers to HECC were expended on allowable adult education activities.

HECC must adopt procedures to review expenditures to ensure compliance with matching and MOE requirements and train staff and local providers on the procedures.  HECC must put in place procedures and appropriate tracking of cash and in-kind contributions from local programs for matching and MOE for the AEFLA program.  In addition, HECC must review the recipient share expenditures reported on the PY 2022 final FFR and all subsequent reports to ensure compliance with matching and MOE requirements. 

State
Fiscal year
2023
Monitoring Review Type
Virtual Targeted
Relevant sections of law and regulation

Sections 222(b) and 241(b) of WIOA; Uniform Guidance 2 CFR §§ 200.302, 200.306, and 200.400

Finding

Module
Module 2 - Fiscal
Finding

HECC does not have procedures in place to ensure the State is properly reporting infrastructure costs negotiated by designated one-stop partner programs.

Discussion

The management of the American Job Center network is the shared responsibility of States, Local Workforce Development Boards (LWDBs), elected officials, the six WIOA core program partners, required one-stop partners and other additional one-stop partners, American Job Center operators, and service providers.  The Memorandum of Understanding (MOU) is an agreement developed and executed by the LWDB and the one-stop partners, and the infrastructure cost funding agreement, which supports the one-stop delivery system, is a component of the MOU.

States are required to report one-stop infrastructure cost expenditures on the annual FFR submitted to OCTAE.  The Oregon Adult Basic Skills Title II Adult Education and Literacy Grant Policy Manual, developed by HECC, contains policies, procedures, and program information for the title II program, including guidance to local programs on cost sharing related to contributing to infrastructure costs, career services, and shared operating costs for required one-stop partners.  The State Policy Manual and sample IFAs had extensive detail on relative benefit and proportionate use, as well as that the IFA costs were to be allocated among the local one-stop partners.  Additionally, as part of the State’s Budget Workbook, HECC required that each WIOA title II grantee reserve 1.5% of federal funds for WIOA cost-sharing as part of their budget submission process.  In a review of local budgets and interviews with State staff, the review team discovered that local programs were including WIOA cost-sharing amounts in their proposed budget requests and in the infrastructure and additional shared cost funding agreement, but HECC was reporting $0 on the most recent FFRs reviewed.  The State is required to report local infrastructure cost expenditures on the final FFR, however, at the time of the review HECC did not have a process in place to ensure infrastructure cost expenditures were being reported on the FFR.  HECC must create procedures to report infrastructure cost expenditures from local adult education providers and ensure that local providers are trained on these procedures.

State
Fiscal year
2023
Monitoring Review Type
Virtual Targeted
Relevant sections of law and regulation

34 CFR § 463.720(a)

Finding

Module
Module 2 - Fiscal
Finding

HECC used an incorrect indirect cost rate on the final federal financial report (FFR) for PY 2020.

Discussion

HECC reported an incorrect restricted indirect cost rate of 20.28% for the period from 7/1/2020 - 6/30/2021 on its final FFR for PY 2020.  The correct rate for that period was 17.52%.  The rate of 20.28% was correct for the second indirect cost row on the FFR, covering the period from 7/1/2021 - 6/30/2022.  HECC must report the correct restricted indirect cost rate on the initial FFR for PY 2022 and the final FFR for PY 2021, if any indirect costs are charged.

State
Fiscal year
2023
Monitoring Review Type
Virtual Targeted
Relevant sections of law and regulation

Section 241 of WIOA; Uniform Guidance 2 CFR §§ 200.332(a)(4) and 200.414(d); EDGAR 34 CFR § 76.563

Finding

Module
Module 2 - Fiscal
Finding

HECC did not follow federal requirements for indirect cost rates and agreements when awarding grants to local providers.

Discussion

States are required to allow local providers to charge indirect costs as part of local administrative costs.  AEFLA is a program that provides federal funding to "supplement and not supplant" other State or local funding; therefore, local providers must use a negotiated restricted indirect cost rate if they choose to charge indirect costs.  HECC incorrectly set indirect costs at 0.4% of federal funds for all subrecipients, which does not comply with the Uniform Guidance or EDGAR.  Additionally, as part of the State’s Budget Workbook, HECC stated, “Indirect Costs must be equal or less than 0.4% of federal funds.”  In 2019, HECC received an email from OCTAE providing technical assistance in response to the State’s question about indirect costs in local provider budgets.  Although the nucleus of OCTAE’s email appears to be technically correct, it abridged certain concepts of indirect costs and may have yielded an unintended misinterpretation.  HECC must revise and issue its indirect cost policy to inform local providers about the allowability of charging indirect costs, using a restricted indirect cost rate.

State
Fiscal year
2023
Monitoring Review Type
Virtual Targeted
Relevant sections of law and regulation

Section 241 of WIOA; Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR §§ 200.1, 200.332(a)(4), and 200.414(c)(1-4); Education Department General Administrative Guidelines (EDGAR) 34 CFR §§ 76.563-564

Finding

Module
Module 2 - Fiscal
Finding

HECC placed restrictions on the negotiated local administrative costs that exceeded five percent of the AEFLA grant.

Discussion

As set forth in section 233(b) of WIOA, an eligible provider may negotiate with the State when the five percent in the statute is too restrictive to allow for local administrative activities in order to determine an adequate level of funds to be used for noninstructional purposes.  The State is required to review the local provider’s request and supporting materials and engage in negotiations with the local provider.  After completing the negotiation process and reviewing the additional requested costs for compliance with the requirements for cost allowability in 2 CFR § 200.403, the State determines if there are funds available to increase the amount of funds made available for noninstructional purposes in section 233(a)(2).  A review of the State’s budget documentation revealed that HECC restricted additional funds above the five percent for noninstructional purposes to be used exclusively for accountability activities, program improvement, or contributing to the infrastructure costs of the one-stop.  Although the State may articulate certain operational priorities during its negotiations with local providers, section 233(b) does permit States to impose limitations on the types of noninstructional costs identified in section 233(a)(2) in advance of the negotiation process.  The State must ensure that its policies for negotiating administrative cost percentages above five percent are consistent with the statute and program regulations.

State
Fiscal year
2023
Monitoring Review Type
Virtual Targeted
Relevant sections of law and regulation

Section 233(b) of WIOA; 34 Code of Federal Regulations (CFR) § 463.25

Table 7: Adult Education Personnel by Function and Job Status

Program Year
2022 (July 1, 2022 - June 30, 2023)
State
Total Number of Part-time PersonnelTotal Number of Full-time PersonnelUnpaid Volunteers
(A)(B)(C)(D)
Function
State-level Administrative/Supervisory/Ancillary Services000
Local-level Administrative/Supervisory/Ancillary Services2280
Local Counselors050
Local Paraprofessionals617628
Local Teachers261896
Teacher Experience in Adult Education
Less than one year149
One to three years1910
More than three years17699
Teacher Certification
No Certification9638
Adult Education Certification00
K-12 Certification6223
Special Education Certification57
TESOL Certification8936

Export to Excel

OMB Control Number 1830-0027

Table MSG: Measurable Skill Gains

Program Year
2022 (July 1, 2022 - June 30, 2023)
State
Skill Gain TypeTotal Skill Gains (Numerator)
Achievement of at least one educational functioning level of a participant who is receiving educational instruction below the postsecondary level3838
Attainment of a secondary school diploma or its equivalent1220
Transcript or report card for either secondary or post-secondary education that shows a participant is achieving the state unit's academic standards4
Satisfactory or better progress report, towards established milestones from an employer/training provider who is providing training (e.g., completion of on-the-job training (OJT), completion of 1 year of an apprenticeship program, etc.)0
Successful passage of an exam that is required for a particular occupation, progress in attaining technical or occupational skills as evidenced by trade-related benchmarks such as knowledge-based exams29
Total5091

Export to Excel

From (mm/dd/yyyy) :
To (mm/dd/yyyy) :

OMB Control Number 1830-0027

Table 14: Local Grantees by Funding Source

Program Year
2022 (July 1, 2022 - June 30, 2023)
State
Provider AgencyTotal Number of ProvidersTotal Number of IELCE ProvidersTotal Number of Sub-RecipientsWIOA Funding TotalWIOA Funding % of TotalState Funding TotalState Funding % of Total
(A)(B)(C)(D)(E)(F)(G)(H)
Local Education Agencies0000.000.00000.000.0000
Public or Private Nonprofit Agency
Community-based Organizations0000.000.00000.000.0000
Faith-based Organizations0000.000.00000.000.0000
Libraries0000.000.00000.000.0000
Institutions of Higher Education
Community Junior or Technical Colleges15705680323.690.975621385016.690.8097
Four-year Colleges or Universities0000.000.00000.000.0000
Other Institutions of Higher Education0000.000.00000.000.0000
Other Agencies
Correctional Institutions100142000.000.02445026989.500.1903
Other Institutions (non-correctional)0000.000.00000.000.0000
Other
0000.000.00000.000.0000
0000.000.00000.000.0000
0000.000.00000.000.0000
Total16.007.000.005822323.69126412006.191

Export to Excel

OMB Control Number 1830-0027

Table 11: Outcome Achievement for Integrated Education and Training Participants

Program Year
2022 (July 1, 2022 - June 30, 2023)
State
1st Period of ParticipationAll Periods of Participation
Primary Indicators of PerformanceNumber of Participants Included in the IndicatorNumber of Participants Achieving Outcome or Median Earnings ValuePercentage of Participants Achieving OutcomeTotal Periods of ParticipationTotal Number of Periods of Participation in which Participants Achieved Outcome or Median Earnings Value for All Periods of ParticipationPercentage of Participants in All Periods of Participation Achieving Outcome
(A)(B)(C)(D)(E)(F)(G)
MSG via Achievement of at Least One Educational Functioning Level38100.263240100.2500
MSG via Attainment of Secondary School Diploma/ Recognized Equivalent3800.00004000.0000
MSG via Secondary or Postsecondary Transcript3840.10534040.1000
MSG via Progress Toward Milestones3800.00004000.0000
MSG via Passing Technical/ Occupational Skills Exam38290.763240310.7750
Employment Second Quarter after exit108530.4907124640.5161
Employment Fourth Quarter after exit76430.565896520.5417
Median Earnings Second Quarter after exit1087099.11N/A1247072.95N/A
Attained a Secondary School Diploma/Equivalent and Enrolled in Postsecondary Education or Training within one year of exit19110.578933170.5152
Attained a Secondary School Diploma/Equivalent and Employed within one year of exit1990.473733140.4242
Attained a Postsecondary Credential while enrolled or within one year of exit76140.184296220.2292

Export to Excel

OMB Control Number 1830-0027

Table 10: Outcome Achievement for Adults in Correctional Education Programs

Program Year
2022 (July 1, 2022 - June 30, 2023)
State
1st Period of ParticipationPeriods of Participation
Primary Indicators of PerformanceNumber of Participants Included in the IndicatorNumber of Participants Achieving Outcome or Median Earnings ValuePercentage of Participants Achieving OutcomeTotal Periods of ParticipationTotal Number of Periods of Participation in which Participants Achieved Outcome or Median Earnings Value for All Periods of ParticipationPercentage of Participants in All Periods of Participation Achieving Outcome
(A)(B)(C)(D)(E)(F)(G)
Measurable Skill Gain213511630.5447221211760.5316
Employment Second Quarter after exit12071570.130112381580.1276
Employment Fourth Quarter after exit11771980.168212322110.1713
Median Earnings Second Quarter after exit12075509.97N/A12385490.44N/A
Attained a Secondary School Diploma/Equivalent and Enrolled in Postsecondary Education or Training within one year of exit9063620.39969553840.4021
Attained a Secondary School Diploma/Equivalent and Employed within one year of exit9061490.16459551600.1675
Attained a Postsecondary Credential while enrolled or within one year of exit1177380.03231232460.0373

Export to Excel

OMB Control Number 1830-0027

Subscribe to Oregon