Narrative: b. 3.

Since DEED is subgranting program operations, the organizational structure of each project will be discussed individually with lines of authority following the organizational structure explanation of DEED, the grantor. Program management will be handled by the Employment & Training Division (ETP) of DEED. The ETP is responsible for: • Recommending statewide employment and training policy • Coordinating state and local employment and training programs • Providing staff support to the GWDB • Administering WIOA monies and other employment and training programs available to the Governor of Minnesota • Initiating fund disbursement process including Requests for Proposals (RFPs) • Making grant award recommendations • Negotiating contracts • Conducting program monitoring, assessment, and evaluation • Interpreting policies

The director has overall responsibility for all activities within ETP. The responsibility for management and administration of SCSEP will be assigned to one Section within ETP. The following information describes the function of each Section, specific staff assigned to the program, percentage of time each staff position is assigned to the program, and a description of staff responsibilities and qualifications: • WIOA programs, responsible for planning and program development for all WIOA grants (which includes SCSEP and WIOA) and for providing staff support to the GWDB • ETP and Fiscal Services, responsible for preparing all grant applications and all • sub—grants entered into by processing all subgrantee invoices and coordinating audits • Program specialist, responsible for coordinating all SCSEP program activities and ensuring that all ETP staff assigned to the program receives appropriate training in SCSEP program operations, rules, and regulations

SUBPROJECT MANAGEMENT As previously indicated, all current subgrantees’ programs will be continued. The rationale for continuing all current subgrantees is based upon subgrantee performance and conformance with the equitable distribution plan. The subprojects to be utilized under this contract are as follows: • Anoka County (governmental unit) • Arrowhead Economic Opportunity Agency (private, nonprofit corporation) • Duluth, City of (a municipal corporation, unit of government) • Experience Works (private, nonprofit corporation) • Inter County Community Council (nonprofit corporation) • Minnesota Chippewa Tribe (Tribal unit of government) • Minnesota Valley Action Council, Inc. (nonprofit corporation) • Rural Minnesota CEP, Inc. (nonprofit corporation) • Scott County (governmental unit) • Southwestern Minnesota Opportunity Council, Inc. (private, nonprofit corporation) • Washington County (governmental unit)

Each of these organizations has a proven record for providing both employment and training services and the needed fiscal and management accountability.

TRAINING OF SUBPROJECT (LOCAL) STAFF The following methods will be used to provide training for subgrantee staff and will be the responsibility of the program specialist: • At least once each year, the program specialist or field representative may meet with all subgrantees to review Title V program operations, highlight effective elements of the various programs, discuss common concerns, and answer programmatic questions. Subgrantees will have input in developing the agenda for these meetings. • As a part of regular monitoring visits, the program monitor will identify individual training and technical assistance needs and communicate these needs to the program specialist who will be responsible for assuring that appropriate training and technical assistance needs are met. For example, if a subgrantee has a new staff person working on the Title V program, the program specialist would provide that person with individual training regarding eligibility determination, program operations and related topics. • During the course of the year, many training opportunities and seminars are offered by various organizations that are relevant for SCSEP subgrantees. For example, the WDD provides staff training in employment and training—related activities such as outreach and recruitment, job development techniques, counseling, and disadvantaged and financial management. While these are primarily for WIOA staff, SCSEP program operators are invited to attend. Another example is the various training opportunities sponsored by the State Board on Aging and other Title V national sponsors.

As these training opportunities become available, subgrantees are notified and encouraged to attend.

PROJECT MONITORING Monitoring and evaluation involves the following procedures and will be the responsibility of staff indicated below:

• Desk Monitoring/Technical Assistance: Technical assistance regarding delays, problems and adversities which may materially affect the sub—grant project directors in obtaining their proposed goals will be provided via telephone, particularly during the start—up phase. Phone calls will continue periodically throughout the grant year to ensure the projects are progressing smoothly; invoices indicate balanced expenditures; and required regulations are met, as well as to answer any program—related questions which may develop. • Onsite Monitoring: A monitoring review guide has been designed to assist WDD monitors in its planned onsite visits. General subcontractors and/or host agency areas to be monitored include program operations worksites and worksite records to ensure required on—the—job supervision is in fact being provided, application operations, complaints, orientation operations, and other proposed and necessary operations.

Upon completion of onsite visits, a monitoring report is written addressing all program operations with a corrective action Section if applicable. This Section will list all program discrepancies which must be alleviated, the time period by which corrections must be made, and a directive requesting the affected program sponsors to submit to WDD, in writing, the means they intend to employ in amending the cited problems. If any corrective action is required and noted in a monitoring report, a 30—day onsite follow—up with the program operator may be conducted to determine what steps have been taken to alleviate the problem. All monitoring reports, corrective action requests and follow—up will be made in writing and will be included in the permanent file for each subgrantee.

FINANCIAL MONITORING • Desk Monitoring: Subgrantees are required to submit invoices at least monthly which identify both actual expenditures and accrual estimates for the invoicing period. The program specialist, field representative and contracts officer receive a copy of the monthly invoices for review. In addition to reviewing the invoices for accuracy, the actual rate of expenditures will be compared with planned expenditures for each subgrantee. If a subgrantee is found to be over expended or under expended by more than 15 percent, the program specialist will follow—up with the subgrantee to determine the reason for the variance and to recommend corrective action, if necessary. • Onsite Monitoring: As a part of regular monitoring visits by the program monitor, each subgrantee’s financial management system, including the system for internal controls, will be reviewed. A fiscal monitoring review guide is used as a basis for monitoring subgrantee financial management systems. Financial monitoring will include, but not be limited to, the following: • Trace amounts claimed on monthly invoices back to books of original entry and source of documentation to ensure that there is an adequate audit trail • Ensure that sources of documentation are complete and accurate • Ensure that costs are being assigned to proper cost categories, allowable, and accrued properly • Ensure that adequate internal controls have been established If any problems are disclosed as a result of monitoring subgrantee financial management systems, corrective action will be cited in the monitoring report that will include a description of discrepancies that must be alleviated, the time period by which corrections must be made and the requirement that the subgrantee submit to ETP, in writing, the way in which the problems will be resolved. Both Minnesota’s Office of the Legislative Auditor and DEED have staff available to more closely investigate financial management systems and provide technical assistance to subgrantees to correct problems. When necessary, onsite follow—up will be conducted to ensure that financial problems have been resolved. If a SCSEP provider desires additional state slots, new state slots, or to renegotiate the number of state slots, a Request for Proposal (RFP) process may need to happen to judge the process fairly.