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Alert Memorandum: ETA Needs to Improve its Plans for Providing Administrative, Financial Management, and Audit Requirements Relief to Grant Recipients Impacted by the Novel Coronavirus (COVID-19)

Summary

An alert memorandum dated May 19, 2020 from Elliot P. Lewis, Assistant Inspector General for Audit at the U.S. Department of Labor Office of Inspector General, to John P. Pallasch, Assistant Secretary for Employment and Training, Report No. 19-20-003-03-001. It explains that on March 19, 2020 the Office of Management and Budget issued Memorandum M-20-17, giving grant recipients affected by COVID-19 short-term, time-limited relief from administrative, financial management and audit requirements under 2 CFR 200, to be reassessed by June 17, 2020. The OIG states that the Employment and Training Administration (ETA) needs to improve its communication with grant recipients about the availability of these flexibilities.

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Full text

U.S. Department of Labor           Office of Inspector General
                                   Washington, D.C. 20210




May 19, 2020




MEMORANDUM FOR:            JOHN P. PALLASCH
                           Assistant Secretary
                            for Employment and Training




FROM:                      ELLIOT P. LEWIS
                           Assistant Inspector General
                            for Audit

SUBJECT:                   Alert Memorandum: ETA Needs to Improve its Plans
                           for Providing Administrative, Financial Management,
                           and Audit Requirements Relief to Grant Recipients
                           Impacted by the Novel Coronavirus (COVID-19);
                           Report No. 19-20-003-03-001

On March 19, 2020, the Office of Management and Budget (OMB) issued
Memorandum M-20-17, Administrative Relief for Recipients and Applicants of
Federal Financial Assistance Directly Impacted by the Novel Coronavirus
(COVID-19) due to Loss of Operations, to provide administrative relief exceptions
for grant recipients impacted by COVID-19.

These exceptions provided short-term relief for administrative, financial
management, and audit requirements under 2 CFR 200, Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards. The
exceptions are time limited and will be reassessed by OMB within 90 days of the
memorandum, or June 17, 2020.

ETA needs to improve its communication with grant recipients regarding the
availability of flexibilities provided in the OMB memorandum, including any
subsequent updates and ETA’s related implementation plans. Given the time
limit imposed on these flexibilities, it is imperative ETA communicate this
information quickly and through the most effective means possible, such as
DOL’s public facing websites or direct communication with grant recipients.




                    Working for America’s Workforce
                                        -2-


As of the date of this memorandum, there was no information on such flexibilities
on the following ETA or DOL websites:

       ETA’s Homepage https://www.dol.gov/agencies/eta

       ETA’s Grant Website https://www.dol.gov/agencies/eta/feature-grants

       ETA’s Advisories Website https://wdr.doleta.gov/directives/

       DOL’s Covid-19 Website https://www.dol.gov/coronavirus

       DOL’s Grants Website https://www.dol.gov/general/grants/howto

ETA officials informed us they discussed internally the flexibilities and have taken
several actions; however, no formal plan has been developed or implemented.
Even so, ETA officials stated they are either implementing, implementing on a
limited basis, or not implementing the various flexibilities identified in OMB’s
memorandum. Further, although ETA officials stated they had communicated
these flexibilities to grant recipients, such communication was through a
non-DOL website and did not specify the plans ETA intends to implement.

The website ETA has been using is sponsored by DOL and provides resource
information to State Workforce Agencies, but should be used in conjunction with
more formal DOL communication forms, such as the main DOL website or ETA’s
website. Moreover, nothing on DOL’s website indicated that this time-sensitive
information was available externally. While ETA may provide the information to
be posted to the website externally, the use of the non-DOL website creates a
risk as ETA is not in full control of what is posted, and limits the audience to
whom the information is made available.

We recommend ETA take immediate action to improve its communication with
grant recipients regarding the time-limited flexibilities provided by OMB in
Memorandum M-20-17. We request a response to this memorandum within
3 business days.


cc: Matthew Hunter, Deputy Assistant Secretary for Employment and Training

     Nancy Rooney, Deputy Assistant Secretary for Employment and Training

     Laura Watson, Administrator for the Office of Grants Management, ETA

     Greg Hitchcock, Special Assistant for the Office of Grants Management,
     ETA

     Julie Cerruti, ETA Audit Liaison
U.S. Department of Labor           Assistant Secretary for
                                   Employment and Training
                                   Washington, D.C. 20210




May 20, 2020

MEMORANDUM FOR:              ELLIOT P. LEWIS
                             Assistant Inspector General for Audit

FROM:                        JOHN PALLASCH
                             Assistant Secretary for Employment and Training

SUBJECT:                     Response to Office of Inspector General (OIG) Alert
                             Memorandum: ETA Needs to Improve its Plans for Providing
                             Administrative, Financial Management, and Audit Requirements
                             Relief to Grant Recipients Impacted by the Novel Coronavirus
                             (COVID-19)


Thank you for the opportunity to respond to the OIG’s May 19, 2020, alert memorandum
regarding the Employment and Training Administration’s (ETA) plans for administrative relief
for grant recipients impacted by COVID-19, pursuant to Office of Management and Budget
(OMB) Memorandum M-20-17.
Since the issuance of OMB M-20-17, ETA has worked diligently to capture and address
questions from the grant community related to COVID-19. Additionally, ETA identified which
flexibilities contained in OMB M-20-17 to implement entirely, on a limited basis, or not all.
ETA communicated the available flexibilities to ETA grant recipients via phone calls, webinars,
emails to grant recipients, and Frequently Asked Questions (FAQs) on WorkforceGPS’ Grant
Application and Management Community of Practice.
ETA offers the following in response to the recommendation contained in the OIG’s alert
memorandum.
OIG Recommendation: Take immediate action to improve its communication with grant
recipients regarding the time-limited flexibilities provided by OMB in Memorandum
M-20-17.
ETA Response: ETA agrees with this recommendation. As an additional measure of
communication, ETA is working with the Office of Public Affairs to establish an ETA grants-
specific FAQ page on the Department’s website.
ETA appreciates the opportunity to respond to your memorandum and its recommendation. If
you have any questions, please contact Laura Watson, Administrator, Office of Grants
Management, at (202) 693-3333.


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Alert Memorandum: ETA Needs to Improve its Plans for providing Administrative, Financial Management, and Audit Requirements Relief to Grant Recipients Impacted by the Novel Coronavirus (COVID-19)
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www.oig.dol.gov
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