Report 2013-102 All Recommendation Responses

Report 2013-102: Employment Development Department: It Needs to Address Data Issues to Better Evaluate and Improve the Performance of Its Employment Programs for Veterans (Release Date: October 2013)

Recommendation #1 To: Employment Development Department

To improve the quality of the performance reporting it submits to Labor, the department should work with Labor to develop reasonable controls to avoid reporting overstated and inaccurate performance measures.

Annual Follow-Up Agency Response From October 2015

The EDD exercised due diligence by collaborating with the Department of Labor (DOL) on how to further improve the quality of performance data submitted to DOL. On September 22, 2015, DOL provided correspondence (Attachment 1) which supports that DOL is satisfied with EDD's efforts to ensure quality data is submitted. The following examples and corresponding evidence demonstrate EDD's collaboration with DOL to improve the quality of data transmitted to DOL:

-On May 5, 2014, EDD launched the upgrade of the California Job Opening Browse System (CalJOBSSM). This system upgrade includes a single-client record that significantly decreases the chance of overstated or inaccurate performance data being reported to DOL. To further support this system upgrade, we have included an excerpt from reference materials developed by our vendor, Geograhic Solution, Inc., which discusses the single-client record (Attachment 2). This document also provides information on how CalJOBSSM complies with applicable federal reporting.

-On June 19, 2013, at the request of DOL, EDD reprogrammed CalJOBSSM to automatically convert wages at or over $1,000,000 to $999,999 for both pre- and post-program wages. This change was necessary as DOL's Enterprise Reporting and Validation System is not capable of capturing wages of $1,000,000 or greater for a given quarter. The EDD's system modification allows DOL to receive wage data that more accurately reflects California's quarterly wages, as previously these wage records were rejected by DOL's data system. Although this change was made to accommodate DOL's Enterprise Reporting and Validation System, EDD continues to maintain the data which reflects the actual amount reported by the employer.

In addition, performance data is reviewed for accuracy and run through a number of edit checks before being transmitted to DOL. Anomalies identified through this process are researched and resolved prior to transmitting these data reports to DOL.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

As noted above, the Employment Development Department (EDD) performed a significant system upgrade subsequent to our audit. Further, the United States Department of Labor (Labor) stated that it was satisfied with EDD's efforts to ensure quality data. We remain concerned that the issues we identified in our audit related to the quality of Social Security data in EDD's "Base Wage File" erode the integrity of the data EDD sends to Labor; we noted in the report that Labor requires states to review data and without such monitoring, the data is eroded. Nevertheless, we recognize that legislation to give EDD more power to investigate Social Security number discrepancies in its Base Wage File did not pass, and we recognize that the Labor, the federal agency that sets policy for collecting and reporting this data, is satisfied with EDD's efforts. We consider this recommendation fully implemented, but suggest EDD continue to take advantage of any opportunities to further improve the quality of its data, including seeking any legislative changes it would require to do so.

1-Year Agency Response

With the launch of the upgraded California Job Opening Browse System (CalJOBSSM) on May 5, 2014, the system now includes a single client record that significantly decreases the chance of overstated or inaccurate performance data being reported to the United States Department of Labor (DOL). As noted in the Employment Development Department's (EDD) October 9, 2013, response to the audit, the EDD has been and will continue to work with the DOL to implement any additional guidance or controls it prescribes to avoid overstated or inaccurate performance data. On June 17, 2013, the DOL requested that the EDD re-program CalJOBSSM to automatically take any wages over $1,000,000 and convert them to $999,999 for both pre-program and post-program wages to meet their Enterprise Reporting and Validation System reporting specifications. This request was implemented in CalJOBSSM effective June 19, 2013. The EDD has implemented all other requirements set forth by the DOL related to performance reporting. The EDD requests that this recommendation be closed.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

On page 20 of the audit report, we state that DOL requires states to perform due dilligence for accuracy and data integrity when using wage data for performance measurement. Our report identified weaknesses in EDD's wage data and recommended that EDD seek guidance from DOL regarding how to improve the quality of its data. EDD has not provided any evidence that it has attempted to work with DOL on this issue.

6-Month Agency Response

On May 5, 2014, WSB will launch the final phase of the new CalJOBSSM system. It will provide a single client record that will decrease the chance of overstated and inaccurate performance measures and give EDD the most accurate data that are under the control of the Department. As noted in its October 9, 2013, response to the audit, EDD has been working with and will continue to work with the U.S. Department of Labor, Employment and Training Administration, and implement any additional guidance/control set forth to avoid overstated and inaccurate performance measures. On June 17, 2013, the U.S. Department of Labor set forth guidance requesting that EDD re-program CalJOBSSM to automatically take any individual quarterly wages over $1,000,000 and convert them to $999,999 for both pre-program wages and post-program wages to meet their Enterprise Data Reporting and Validation System (e-DRVS) system reporting specifications. This was implemented effective June 19, 2013, in the CalJOBSSM system.

California State Auditor's Assessment of 6-Month Status: Pending

As noted in its response, EDD expects to implement its new system on June 30, 2014.

60-Day Agency Response

As noted in the October 9, 2013 response to the audit, the EDD has been and will continue to work with the U.S. Department of Labor; Employment and Training Administration and implement any additional guidance/control set forth to avoid overstated and inaccurate performance measures.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation for Legislative Action

To help protect the State's citizens from identity theft, the Legislature should expressly authorize the department, on its own initiative, to share information from the Base Wage File with appropriate law enforcement officials when evidence exists of the potential misuse of Social Security numbers. If the department receives such legal authority, it should, at least annually, review the Base Wage File for associations of multiple names with a single Social Security number. The department should also establish a reasonable threshold for the number of associated names that will trigger further scrutiny from the department or referral to law enforcement.

Description of Legislative Action

The Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

SB 1409 would have required the Employment Development Department, if it discovers that more than one individual is using a social security number, to determine which user is legally issued that number and to provide a notification containing specified information to the other users of the number. The bill also would have required the department to keep a record of those numbers and dates of discoveries and notices, and submit a report regarding the record to the Legislature.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Proposed But Not Enacted

Description of Legislative Action

SB 1409 was introduced on February 19, 2016, and would require the Employment Development Department, if it discovers that more than one individual is using a social security number, to determine which user is legally issued that number and to provide a notification containing specified information to the other users of the number. The bill would also require the department to keep a record of those numbers and dates of discoveries and notices, and submit a report regarding the record to the Legislature. This bill is pending.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Introduced

Recommendation #3 To: Employment Development Department

To improve the department's performance on its negotiated goals, it should, by January 2014, ensure that all veterans employment representatives are fully trained to use the new version of CalJOBS.

6-Month Agency Response

Training of the new CalJOBSSM, Series 1-4 has been successfully given to all Veterans Program staff and Program managers. These training modules are posted on EDDs intranet for new Veterans Program staff and managers to view.

Series 1: Intake/Case Management Assignment Completed 11/12/2013

Series 2: Activities and Service Recordings Completed 11/19/2013

Series 3: Closures/Exits Completed 12/17/2013

Series 4: Events/Tools/Alerts Completed 1/14/2014

The EDD requests the closure of this recommendation now that training has been completed by all Veterans Program staff and managers.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

The EDD has been working to enhance and expand the supplemental veteran-specific training modules that will be used to fully train the Veteran Employment Program Representatives on the new CalJOBS system. The training will teach staff how to capture and input their daily work into the new system. The training consists of four training modules. The first three have been implemented and training has already been provided. The fourth training module is scheduled to be completed by January 31, 2014.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #4 To: Employment Development Department

To improve the department's performance on its negotiated goals, it should, through its governance council, regularly assess whether its actions under the 100-day plan are improving performance on the three common measures.

1-Year Agency Response

The Veterans' Program Governance Council (VPGC) continues to meet monthly to plan and review actions and assess their impact on performance outcomes. Results for VPGC actions are reflected in the performance data 9 to18 months later due to the inherent lag time in the performance outcome data validation system.

Common Performance Measures training for staff has been completed. EDD staff have been trained on the Veterans' Service Navigator roles and responsibilities as well as the Veteran Intake Form (VIF). This training assures that veterans are properly routed through the America's Job Center of CaliforniaSM locations to receive the most appropriate services. The Veterans' Service Navigator uses the VIF to initially screen all incoming veterans, eligible spouses, and other eligible clients visiting an America's Job Center of CaliforniaSM location. The VIF helps determine whether a veteran, spouse or other client is eligible for Veterans' Intensive Program services from a Jobs for Veterans State Grant Disabled Veterans' Outreach Program (DVOP) specialist. The VIF also allows field office and program managers to track the number of veterans referred by the Veterans' Service Navigator to a DVOP specialist or Wagner-Peyser program and partner staff. DVOP specialists, Local Veterans Employment Representatives, and Wagner-Peyser workgroups have been formed to develop policies, procedures, and performance expectations to better guide staff in serving veterans, eligible spouses, and other eligible clients in ways leading to more positive employment and retention outcomes.

The most recent performance data indicate that the VPGC's efforts have resulted in continued improvement (see Attachment).

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

The Veterans Program Governance Council meets twice monthly to plan and review actions and assess their impact on future outcomes. Results for VPGC actions are reflected in the performance data 9 to 18 months later due to the inherent lag time in the performance outcome data reporting system

Common Measures training for staff was completed with more focus on process to ensure proper outcomes. Trainers are preparing training on using a new Veteran Intake Form (VIF) to assure that veterans are properly routed through Americas Job Center of California locations to receive the most appropriate services leading to employment and retention. The Veterans Service Navigator (VSN) will use the VIF to initially screen all incoming veterans visiting an Americas Job Center of California location. The VIF will help determine whether a veteran is eligible for Veterans Intensive Program services from a Jobs for Veterans State Grant Disabled Veterans Outreach Program (DVOP) specialist or would be better served by Wagner-Peyser or Workforce Investment Act partner staff. The VIF also allows field office and program managers to track the number of veterans referred by VSNs and DVOP specialists to grant-funded staff.

In addition, the DVOP, Local Veterans Employment Representatives, and Wagner-Peyser workgroups have been formed. These workgroups develop policy, processes, and performance expectations to better guide staff in serving veterans in ways leading to more positive employment and retention outcomes. These workgroups report their progress to the Council monthly for feedback and to assure that process changes are effectively implemented systemwide.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The EDD plans to continue assessing how the work of its Veterans Program Governance Council can help staff improve performance as measured by the Department of Labor's three common measures. Since its inception, the Veterans Program Governance Council has focused on improving performance. While the 100-day plan, as implied by its name, was a short-term plan, the Council continues, on an ongoing basis, to provide new policy, procedures and business processes designed to help Veteran Employment Program Representatives improve program performance. Veteran-specific training on Common Measures was provided on November 18, 2013 to EDD managers who supervise veteran staff and additional Common Measures training is being developed. The Council plans to regularly review and analyze the Common Measures reports to ensure that strategies implemented improve the negotiated outcomes.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: Employment Development Department

To identify ways to better serve veterans in California, the department should assess the success or struggles of veterans within demographic categories in finding employment, such as age, race, or educational attainment, by comparing veterans' performance to that of nonveterans in the same demographic categories and across demographic categories and use this analysis to determine whether specific populations of veterans could be better served through more targeted efforts and to identify best practices for improving employment outcomes for these specific populations. Further, the department should provide the results of this analysis annually, beginning in 2014, to stakeholders, including local workforce agencies, the state workforce board, the interagency council, the Legislature, and the public.

Annual Follow-Up Agency Response From November 2017

As stated in our last response, EDD began issuing an annual report in 2016 to focus on the successes or struggles of veterans of select demographic categories. The report, "California's Veterans Workforce 2016," assessed veterans in five areas: Share of Populations, Veterans in the Labor Force, Racial and Ethnic Makeup of Veterans, Jobs Held by Veterans, and Unemployment Compensation Trends. The "2017 Veterans Day Workforce Report" addresses: Veterans in the Labor Force, Veterans' Skill Sets, Educational Attainment, Industry Sector Employment, and Occupational Employment. This annual report is published after the November Veterans Day Campaign. Both are available to stakeholders and the public on EDD's website (see Attachments 1 and 2).

To further evaluate whether specific populations of veterans could be better served through more targeted efforts, the United States Department of Labor, Employment and Training Administration released new reporting guidelines due to the implementation of the Workforce Innovation and Opportunity Act (WIOA) of 2015. These guidelines provide federal reporting layouts for the collection of data and reporting of the same basic demographic categories across programs, including veterans and non-veterans (e.g., Adult, Dislocated Worker, Youth, and Wagner-Peyser Act). These changes provide EDD and the California Workforce Development Board (CWDB) the ability to analyze the data across programs as it pertains to the levels of service provided and performance in order to determine best practices to improve the employment outcome for these populations. On November 3, 2017, the results of the analysis were provided to the CWDB for inclusion in the first annual report as set forth by WIOA. It is available to stakeholders and the public on CWDB's website.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

We consider this recommendation fully implemented. However, we encourage EDD to use the data now at its disposal to inform its efforts to provide services to veterans.

Annual Follow-Up Agency Response From September 2016

The EDD's Labor Market Information Division issued the first annual report in December 2015 titled, "California's Military Veterans - Valuable Assets for Today's Successful Businesses" (see Attachment). This report assesses veterans in five subject areas: Veterans in the Labor Force, Veterans' Skill Sets, Educational Attainment, Industry Sector Employment, and Occupational Employment. Each year the report will focus on the successes or struggles of veterans of select demographic categories. The report is published during the Veterans Day Campaign, which takes place annually in November. The report is available to stakeholders and the public on EDD's website.

To further evaluate whether specific populations of veterans could be better served through more targeted efforts, the United States Department of Labor, Employment and Training Administration released new reporting guidelines due to the implementation of the Workforce Innovation and Opportunity Act of 2015. These guidelines provide federal reporting layouts for the collection of data and reporting of the same basic demographic categories across programs (e.g., Adult, Dislocated Worker, Youth, and Wagner-Peyser Act). These changes provide EDD and the California Workforce Development Board the ability to analyze the data across programs as it pertains to the levels of service provided and performance. In October 2017, the results of the analysis will be provided to the California Workforce Development Board for inclusion in the first annual report as set forth by Workforce Innovation and Opportunity Act. This will provide California the ability to better serve our veteran population.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2015

The EDD launched the upgraded CalJOBSSM on May 5, 2014. Through the new CalJOBSSM, current functionality is now available to gather performance data for veterans by demographic categories. The DOL/Employment and Training Administration 9002 and DOL/Veterans' Employment and Training Service 200 series reports are available within CalJOBSSM for reporting and data collection. The Program Reporting and Analysis Unit will continue to work with the system vendor and EDD's Information Technology staff to further provide data analyses. Additionally, the Program Reporting and Analysis Unit continues to improve product development for program processes, procedures, and formal statistical analysis that will allow the Veterans' Program Unit staff to collect and analyze additional demographic information needed to identify veterans' workforce services data such as the "Program Service Identifiers" implemented July 21, 2015, which provides specific identification of veterans with "significant barriers to employment" in CalJOBSSM (see Attachment 3).

The Veterans Program Unit is also in collaboration with EDD's Labor Market Information Division to further develop veteran demographic statistics with relationship to the Workforce Innovation and Opportunity Act 2015. The Labor Market Information Division is currently developing a formal report which we anticipate will be available by the end of the calendar year. This report will incorporate four subject areas: state-to-state comparisons, gender, educational attainment, and unemployment compensation for ex-service members. The EDD envisions this deliverable will be made available to stakeholders annually to support measureable data which supports EDD's vision to provide continuous quality improvement of outreach services to our State's veterans.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The EDD continues to work within its available resources to determine the feasibility of fully implementing this recommendation. The initial assessment was slated to begin after the launch of the upgraded CalJOBSSM originally set for February 2014. Due to a variety of operational issues including faulty data conversion, the launch was pushed back to

May 5, 2014; it was successfully launched on that date. Though the current CalJOBSSM has some functionality to gather performance data for veterans by demographic category, the Program Reporting and Analysis Unit will work with the system vendor and the EDD Information Technology Branch staff to develop processes, procedures, and tools that will allow the Veterans' Program Unit staff to collect and analyze the additional information needed to identify veterans' services delivery improvements. Due to the extraordinary efforts required to launch the upgraded system, implementation of these new processes, procedures, and tools has been pushed back to the first quarter of 2015 and will take approximately five months to complete.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The EDD continues to work within its available resources to determine the feasibility associated with fully implementing this recommendation. The initial assessment was slated to begin after the launch of Phase IB of the new CalJOBSSM originally set for February 2014. Due to data conversion issues/delays, the launch has been pushed back to May 5, 2014. Though the new CalJOBSSM already has some functionality to gather performance data for veterans by demographic category, the Program Reporting and Analysis Unit will begin work with the system vendor and EDD Information Technology staff after Phase IB launches to develop processes, procedures, and tools that will allow Veterans Program Unit staff to collect and analyze the additional information needed to identify veterans services improvements. It is anticipated that this work will commence in June 2014 and will take approximately 5 months to complete.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The EDD will work within its available resources to determine the feasibility associated with fully implementing this recommendation. The initial assessment is slated to begin after the launch of Phase 1B of the new CalJOBS set for February 2014. Though the new CalJOBS already has some functionality to gather performance data for veterans by demographic category, EDD Veteran services staff will begin work with the system vendor and EDD IT staff after the Phase 1B launches to develop processes, procedures, and tools that will allow EDD Veterans services staff to collect and analyze the additional information needed to identify veteran service improvements.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #6 To: Employment Development Department

To ensure that it is using its limited resources effectively, the department and its information division should develop and implement, by July 2014, a means to receive and analyze feedback from workforce branch staff and from local workforce agencies to determine whether they have ideas for improving the employment outcomes for veterans. Specifically, the feedback method should include a means of identifying whether the staff in the field are accomplishing the department's veteran-specific objectives and whether the tools being used—such as labor information reports and the Vocations for Vets publications—can be made more useful and effective.

1-Year Agency Response

A communications tool was approved by the VPGC and released on May 1, 2014. The tool provides a feedback mechanism to the VPGC for staff and managers who serve veterans.

Feedback will be gathered and assessed by the EDD Veterans' Program Unit each quarter. Ideas and effective practices will be presented to the VPGC for consideration and action/implementation. The EDD requests that this recommendation be closed.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

In a quarterly update from its Veterans Program Governance Council, EDD announced a special email address and encouraged EDD staff and supervisors working with veterans to submit feedback and ideas to the council. Additionally, the quarterly update itself reports on activities of the council and its workgroups.

6-Month Agency Response

The Communications Tool format has been approved by the Veterans Program Governance Council. The first release is anticipated in April 2014. The tool includes a feedback mechanism so that staff and managers who serve veterans are given the opportunity to express ideas and concerns to the Veterans Program Governance Council. Additionally, its worth pointing out again that EDD has over 20 local labor market consultants stationed throughout the State that continually collect customer feedback on the labor market products it produces, which is used to make them more useful and effective.

Feedback will be gathered and assessed by the EDD Veterans Program Unit each quarter. Ideas and effective practices will be presented to the VPGC for consideration and action/implementation.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The Veterans Program Governance Council has begun work on several fronts to receive and analyze feedback on its veteran services. The Council is completing development of a communications tool which will be used to submit, receive, and evaluate feedback on veterans' services. The new tool will inform the EDD Veteran services staff of upcoming training, tools, new forms, and new policy and procedures. The tool will also allow for input back to the Veterans Program Governance Council via a real time email system. The Council has also formed three new workgroups that will focus on the roles, responsibilities, and performance expectations of the Disabled Veterans' Outreach Program, Local Veterans' Employment Representative and Wagner-Peyser veteran services staff. The three workgroups will review the availability and usefulness of tools being used by EDD.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #7 To: Employment Development Department

To better optimize its leadership role in the interagency council's employment workgroup, the department should ensure that the employment workgroup develops a timeline for completing its action items and develops a process for measuring its success in improving employment outcomes for veterans. Specifically, the department should take the lead for establishing a time frame for evaluating tools to help assess and translate military skills into finding civilian jobs and establishing a transition assistance program for veterans.

Annual Follow-Up Agency Response From September 2016

On June 30, 2016, the work of the Interagency Council under the California Department of Veterans Affairs and the Interagency Agreement between the Council under the California Department of Veterans Affairs and EDD concluded.

As stated in last year's annual response, establishing timelines and goals for the workgroup was not within the sole purview or control of EDD to accomplish. However, EDD did exercise due diligence and brought this to the Interagency Council's attention during a workgroup meeting. Therefore, EDD requests that this recommendation be closed.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

Unfortunately, EDD never implemented this recommendation; however, circumstances have changed such that we consider it resolved. According to a document from the Interagency Council, the working groups, including the employment working group, were temporary, and as of April 2016, that document stated that the member entities of the working groups took ownership of the group priorities and the working groups were closed. Further, the employment working group's priority action grid indicates that all tasks identified were complete, closed, or transitioned to member agencies. As the working groups are no longer functioning, it is no longer possible for EDD to exert the leadership we recommended.

Annual Follow-Up Agency Response From October 2015

The EDD has exercised due diligence and brought this to the Interagency Council's attention. As stated in our last response, establishing timelines and goals for the workgroup is not within the sole purview or control of EDD to accomplish. Therefore, EDD requests that this recommendation be closed.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

The EDD remains committed to advancing the work of the Interagency Council on Veterans in many key areas such as translating military skills into civilian jobs. But, establishing timelines and goals for the workgroup is not within the sole purview or control of EDD to accomplish. Therefore, the EDD requests that this recommendation be closed.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

As we state on page 34 of the audit report, the interagency council lacks timelines and measurable goals for many activities, even though the employment workgroup has been in place since January 2012 and thus, in our opinion, it has had time to establish such timelines and goals. Staff from EDD are in a position to exercise a leadership role on the interagency council and are well-positioned to implement our recommendation.

6-Month Agency Response

The EDD remains committed to advancing the work of the Interagency Council on Veterans in many key areas such as translating military skills into civilian jobs. But, establishing timelines and goals for the workgroup is not within the sole purview or control of EDD to accomplish. Therefore, EDD requests that this recommendation be closed.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

As we state on page 34 of the audit report, the interagency council lacks timelines and measurable goals for many activities, even though the employment workgroup has been in place since January 2012 and thus, in our opinion, it has had time to establish such timelines and goals. Staff from EDD are in a position to exercise a leadership role on the interagency council and are well-positioned to implement our recommendation.

60-Day Agency Response

The California Interagency Council on Veterans (ICV) established four workgroups to focus on identifying and prioritizing the current needs of California veterans. These workgroups and sub-workgroups of the ICV meet and are attended by a variety of governmental and non-governmental agencies, collaborative groups, and individuals, all focused on enhancing the delivery of veterans' services through the coordination of their independent activities and efforts. While the Deputy Director of EDD's Workforce Services Branch is the Chair of the ICV's Employment Workgroup, the members are employed by the various independent organizations and therefore are outside the control of EDD. The workgroup is responsible for determining its own priorities and actions and is proceeding at its own pace.

The ICV website carries the following footnote on the ICV Employment Priority Action Grid that is mentioned in the Auditor's report and recommendations:

"The foregoing Priority Grids serve only as a reference to illustrate the historical evolution of the ICV's priorities and the various means for addressing them. Importantly, the documents are intended to reflect the constantly changing priorities and decisions of the ICV's meeting attendees and must not be construed as setting forth mandatory goals or measures."

The EDD remains committed to advancing the work of the ICV in many key areas such as translating military skills into civilian jobs. But, establishing timelines and goals for the workgroup is not within the sole purview or control of EDD to accomplish. Therefore, EDD requests that this recommendation be closed.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

The employment workgroup of the Governor's Interagency Council on Veterans has been in place since January 2012. Having been in place now for two years, we believe the employment workgroup has now had ample time to both decide what specific steps need to be taken and to develop an action plan for implementing its ideas. Serving as the chair of the employment workgroup, the Employment Development Department's (department) response to this recommendation discusses constantly changing priorities and states that its plans do not establish mandatory goals or measures. However, without strong leadership from the department and a timeline for a plan of action, we remain skeptical as to how many of the employment workgroup's ideas will ultimately come to fruition and help veterans find employment.

Recommendation #8 To: Employment Development Department

To evaluate the success of the veterans assistance program going forward, the department should analyze the performance of the grant recipients across all three common measures. Further, the program manager unit and the reporting unit should work together to ensure that the data the program manager unit is using to assess program performance are the most appropriate and the best available.

6-Month Agency Response

The EDD currently has a process in place to evaluate the three common performance measures. The EDD is now reviewing its veterans performance data on a quarterly basis against the data submitted by its grantees. The EDD revised the quarterly reporting form which will assist in capturing the data for the three common measures reported by the grant recipients. The project managers will compare that data against the data reported in the system and communicate with the project operators when discrepancies exist. In addition, the project managers are working closer with the Program Reporting and Analysis Unit to help ensure the accuracy of that data. With these new procedures in place, EDD requests that this recommendation be closed.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

The EDD modified its performance reports under the veterans assistance program to include the three common measures. Although EDD provided examples of these reports for certain grant recipients, we did not audit the accuracy of the performance data included in these reports. Nevertheless, EDD appears to have fully implemented this recommendation.

60-Day Agency Response

As noted in EDD's October 9, 2013 response to the audit, the Department currently has a process in-place to evaluate the three-common performance measures. However, EDD will be implementing this recommendation by reviewing its veterans performance data on a quarterly basis against the data submitted by its grantees. Though not fully implemented, EDD anticipates implementing this procedure by January 31, 2014 to address the previous quarter reports for October - December 2013.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #9 To: Employment Development Department

To assess whether it is doing enough to take advantage of federal requirements that federal contractors give preference to veterans when hiring, the department should determine why the reported number of veterans receiving employment with federal contractors is so low relative to the number of job referrals made and it should provide appropriate direction to the veterans employment representatives to better leverage the federal contractor job listing.

Annual Follow-Up Agency Response From October 2015

The Office of Federal Contract Compliance Program (OFCCP) has been providing compliance assistance to federal contractors to help them develop a plan, policies, and procedures to implement DOL regulations (see Attachment 4), including giving preference to veterans when hiring. Since the Veterans Program Unit's reorganization to the Workforce Services Branch's Deputy Director's Office, many process improvements have been implemented, as the Deputy Director found that more emphasis was needed in improvement to the Veterans Program for DOL/Veterans' Employment and Training Service reporting and program development. As such, the Veterans Program Unit has established a close relationship with the OFCCP to help federal employers respond to compliance evaluation reports (see Attachment 5). In addition, the Local Veterans' Employment Representatives in the field offices are now assisting federal employers to meet compliance requirements by helping employers register in CalJOBSSM and posting federal positions.

Outreach to federal employers allows for participation in the established 24-hour job- posting holds for veterans in CalJOBSSM. This process also provides continuous outreach to new and established federal employers and maintains federal compliance with OFCCP; however, it remains the discretion of the employer to hire a veteran. Therefore, EDD requests that this recommendation be closed due to full implementation.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

1-Year Agency Response

The Workforce Services Division, Program Reporting and Analysis Unit, will develop guidance on the reporting functions within CalJOBSSM that can assist the Veterans' Program, Wagner-Peyser program, and Workforce Investment Act partner staff in helping veterans apply for federal job contractor listings.

On March 24, 2014, the DOL, Office of Federal Contract Compliance Programs, published a Final Rule that made changes to the regulations implementing Section 503 of the Rehabilitation Act of 1973 and Section 4212 of the Vietnam Veterans' Readjustment Assistance Act. The new regulations establish specific metrics for federal contractors and subcontractors to recruit, hire, promote, and retain veterans and people with disabilities. The Office of Federal Contract Compliance Programs has been providing assistance to federal contractors to help them develop a plan, policies, and procedures to implement these regulations.

As a result of the new regulations, more businesses will be looking to State Labor Exchange Systems to help them recruit and hire veterans and individuals with disabilities. This presents a tremendous opportunity for CalJOBSSM to improve employment outcomes for the veteran population and to provide a valuable service for our business customers.

The WSB is developing an outreach process for Local Veterans Employment Representative staff throughout the America's Job Center of CaliforniaSM to contact all federal contractors who have filed letters disclosing their status. The process will inform the federal contractor of their responsibilities and offer workforce services assistance which includes matching qualified veterans with their future hiring needs.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The Workforce Services Division, Program Reporting and Analysis Unit will develop guidance on the reporting functions within CalJOBSSM that can assist the Veterans Program staff, WagnerPeyser staff, and Workforce Investment Act partner staff on federal job contractor listings after implementation of Phase 1B. On March 24, 2014, the U.S. Department of Labor, Office of Federal Contract Compliance Programs published a Final Rule that made changes to the regulations implementing Section 503 of the Rehabilitation Act of 1973 and Section 4212 of the Vietnam Veterans Readjustment Assistance Act. The new regulations establish specific metrics for federal contractors and subcontractors to recruit, hire, promote, and retain veterans and people with disabilities. The Office of Federal Contract Compliance Programs has been providing compliance assistance to federal contractors to help them develop a plan, and policies and procedures to implement the regulations. As a result of the new regulations, many more businesses will be looking to Americas Job Centers and State Labor Exchange Systems to help them recruit and hire veterans and people with disabilities. This presents a tremendous opportunity for the new CalJOBSSM to improve employment outcomes for the veteran population and to provide a valuable service for our business customers.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The Workforce Services Division, Program Reporting and Analysis Unit is developing guidance on the reporting functions within CalJOBS that can assist the Veterans' Program staff, Wagner-Peyser staff, and Workforce Investment Act partner staff on Federal Job Contractor Listings. Once this is complete, the Veterans Program Governance Council will work with the Workforce Services Division's Capacity Building Unit to develop training on this guidance. This training will be provided via webinar to Workforce Investment Act and Wagner-Peyser staff throughout America's Job Center of California locations. This training should be available starting in May 2014.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2013-102

Agency responses received are posted verbatim.