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COVID-19: ETA Should Continue To Closely Monitor Impact On Job Corps Program

Summary

U.S. Department of Labor Office of Inspector General report no. 19-20-007-03-370 to the Employment and Training Administration (ETA), issued July 28, 2020, on ETA's initial response to the pandemic's challenges to the Job Corps program. It reports that Job Corps suspended campus operations on March 16, 2020 and transported nearly 30,000 students home or found them housing, while 445 students who had nowhere to go stayed at open centers. Between March 16 and May 31, 2020, 4 of these students tested positive for COVID-19, and 35 staff tested positive while working. The report says Job Corps moved all centers to remote learning on May 11, 2020, but not all students had a laptop, tablet or internet access, and that remote learning may be hard for technical training.

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Full text

REPORT TO THE EMPLOYMENT
AND TRAINING ADMINISTRATION




COVID-19: ETA SHOULD CONTINUE TO
CLOSELY MONITOR IMPACT ON JOB
CORPS PROGRAM




                      DATE ISSUED: JULY 28, 2020
                 REPORT NUMBER: 19-20-007-03-370
U.S. Department of Labor                          WHAT OIG FOUND
Office of Inspector General
Audit                                             Job Corps temporarily suspended operations
                                                  on its campuses on March 16, 2020 and
                                                  transported nearly 30,000 students to their
                                                  homes or found them housing. Fifty-five centers
BRIEFLY…                                          remained open to house and feed 445 students
                                                  who had nowhere to go. Between March 16 and
                                                  May 31, 2020, 4 of these students tested
COVID-19: ETA SHOULD CONTINUE TO                  positive for COVID-19. Thirty-five staff tested
CLOSELY MONITOR IMPACT ON JOB                     positive while they were actively working.
CORPS PROGRAM
                                                  Job Corps transitioned all centers to remote
July 28, 2020                                     learning on May 11, 2020 in order to continue
                                                  educating and training students. However, not
WHY OIG CONDUCTED THE AUDIT                       all students had a laptop, tablet, or even
                                                  internet access to participate in remote
On January 31, 2020, the Secretary for Health     learning. Job Corps said it is working to ensure
and Human Services declared a nationwide          each student has the necessary tools needed
public health emergency in response to the        for remote learning by August 2020. Remote
coronavirus (COVID-19) pandemic. As of            learning creates additional challenges for Job
June 28, 2020, there were over 2 million          Corps students as most are high school
confirmed COVID-19 cases in the United            dropouts and have deficiencies in basic skills.
States, and social distancing mandates have       Without the structured environment Job Corps
caused mass disruption to the economy and         provides, some students may not be able to
peoples’ lives in every state.                    learn remotely and may leave the program.
                                                  Remote learning will be especially challenging
As part of Phase 1 of the OIG’s Pandemic          as some technical training skills, such as
Oversight Response Plan, this report presents     automotive and machine repair, carpentry, and
the results of our audit of the Employment and    advanced cement masonry, may be difficult to
Training Administration’s initial response to     learn when limited to only virtual instruction.
challenges to the Job Corps program posed by
the pandemic.                                     In preparation for when all Job Corps centers
                                                  reopen, Job Corps recognizes students may
WHAT OIG DID                                      surpass the allotted amount of time they may
                                                  remain in the program. Job Corps said it will grant
We conducted a performance audit to answer        extensions to address this. In April 2020, Job
the following question:                           Corps also started requiring its career transition
                                                  and outreach and admissions services providers
   What actions has Job Corps taken in            work remotely.
   response to challenges posed by the
   COVID-19 pandemic?                             WHAT OIG RECOMMENDED

To answer this question, we interviewed ETA       We made recommendations focused on
and Job Corps officials, and reviewed select      protecting the health of students and staff
guidance issued by federal, state, local          currently at centers, ensuring both centers and
governments; and policies and guidance Job        remote students have the necessary resources to
Corps issued on COVID-19.                         engage in a virtual learning environment, and
                                                  ensuring centers have the proper controls in place
READ THE FULL REPORT                              to adhere to national safety guidance prior to
                                                  reopening their campuses.
https://www.oig.dol.gov/public/reports/oa/2020/
19-20-007-03-370.pdf                              ETA generally agreed with our recommendations.
                                            U.S. Department of Labor – Office of Inspector General


                                      TABLE OF CONTENTS



INSPECTOR GENERAL’S REPORT .................................................................... 1

RESULTS ............................................................................................................. 2

         Protecting the Health of Job Corps Students and Staff at Centers............. 2

         Continuing to Deliver Training, Career Transition, and Outreach
         and Admissions Services ........................................................................... 6

CONCLUSION ...................................................................................................... 9

OIG’S RECOMMENDATIONS ............................................................................ 10

         Summary of ETA’s Response .................................................................. 11

APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA.................................... 12

APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 15

APPENDIX C: ACKNOWLEDGEMENTS ........................................................... 18




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




                         INSPECTOR GENERAL’S REPORT




  John Pallasch
  Assistant Secretary
   for Employment and Training
  U.S. Department of Labor
  200 Constitution Ave, NW
  Washington, DC 20210


  This report presents the results of the Office of Inspector General’s (OIG) audit of
  the Employment and Training Administration’s (ETA) actions to mitigate the
  challenges the coronavirus (COVID-19) pandemic had on the Job Corps
  program. On January 31, 2020, the Secretary for Health and Human Services
  declared a nationwide public health emergency in response to COVID-19.

  The Job Corps program, administered by ETA, provides academic and job skills
  training in a mostly residential setting to disadvantaged youth (i.e., those who
  receive public assistance and/or live below the poverty line) who face numerous
  barriers to employment, such as being a high school dropout or deficient in basic
  skills. With 121 centers located nationwide and in the Commonwealth of Puerto
  Rico, Job Corps provides housing, meals, health care services, and support
  services to students. According to Job Corps, there were about 30,000 students
  enrolled when the pandemic occurred.

  As part of Phase 1 of the OIG’s Pandemic Oversight Response Plan and given
  the disruptive nature of the COVID-19 pandemic, we conducted this audit to
  answer the following question:

         What actions has Job Corps taken in response to challenges posed
         by the COVID-19 pandemic?

  We found that Job Corps faces a number of challenges, which include: protecting
  the health of students and staff at centers and fulfilling its responsibility to train



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  students. In response, Job Corps temporarily closed center campuses, sent most
  students home, and transitioned to remote learning.

  To answer this question, we obtained information from ETA and Job Corps via
  interviews and a questionnaire and reviewed select guidance issued by federal,
  state, and local governments, as well as policies and guidance issued by Job
  Corps specifically addressing COVID-19-related issues. Our audit covered the
  three-month period from March 2020 through May 2020.


                                     RESULTS


  Job Corps faces two primary challenges related to the COVID-19 pandemic:

     •   Protecting the health of students and staff at centers, and
     •   Continuing to recruit, train, and place students.

  ETA responded by temporarily suspending operations on Job Corps campuses,
  sending students home, and transitioning to a remote training environment,
  among other things. Some centers stayed open to provide housing and meals for
  students who had nowhere to go. Protecting everyone at these centers (i.e.,
  students and essential staff) remains a challenge. Even with remote learning, Job
  Corps faces other hurdles as many students: need the structured environment
  Job Corps provides; do not have ready access to the tools – laptop or tablet, or
  even internet access – to connect remotely; and may be unable to learn and
  complete certain trades remotely, such as automotive and machine repair and
  carpentry, without equipment and hands-on instruction.

  Job Corps faces more challenges similar to those faced by other residential,
  educational and training programs with reopening centers – from implementing
  physical distancing in classrooms, dorms, and common areas and maintaining
  ample supplies of disinfectant and cleaning materials. High unemployment due to
  the temporary shuttering of non-essential businesses will also impact the
  program’s ability to place students in good jobs during and after the pandemic.

  PROTECTING THE HEALTH OF JOB CORPS
  STUDENTS AND STAFF AT CENTERS


  As the COVID-19 pandemic rapidly developed and guidance recommending
  people stay-at-home emerged from the Centers for Disease Control and
  Prevention (CDC) and state and local governments nationwide, ETA initiated a
  number of actions to protect the health of students and staff at Job Corps


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  centers. These actions included issuing prevention guidance, suspending
  operations on Job Corps center campuses, and sending students home.

  Adhering to Federal, State, and Local Government Safety and Health Guidelines

  The CDC and governments at the state and local levels developed and
  implemented a variety of guidelines to help prevent the spread of the disease.
  The CDC recommended everyday steps, such as washing hands often, covering
  mouth and nose with a cloth face cover when around others, and covering
  coughs and sneezes. In addition, the CDC noted keeping space between people
  is one of the best tools to avoid exposure to this virus and slowing its spread
  locally and across the country and world. To that end, the CDC and most states
  recommended people practice social distancing (also referred to as physical
  distancing) by keeping space between themselves and others outside their
  household as follows:

     •   Stay at least 6 feet (about 2 arms’ length) from other people
     •   Do not gather in groups
     •   Stay out of crowded places and avoid mass gatherings

  On March 16, 2020, the federal government recommended every American
  follow these guidelines through the end of the month. On or about the same time,
  most states, as well as many local jurisdictions, started instituting stay-at-home
  or shelter-in-place orders that temporarily closed schools and non-essential
  businesses and restricted people from leaving their homes, except for essential
  activities, essential travel, and exercise.

  Adhering to federal, state, and local recommendations and restrictions created
  challenges for Job Corps as students generally live in center housing. In
  response, ETA disseminated critical information and implemented a number of
  protocols that included:

     •   Informing centers about COVID-19 and prevention information. On
         March 6, 2020, Job Corps issued Information Notice (IN) 19-12 providing
         center directors and operators with COVID-19 facts, prevention
         information, and resources. Among other things, the IN also required
         center operators to review and update their pandemic influenza response
         plans and modify them as needed to address the evolving impacts of
         COVID-19.

     •   Temporarily suspending on campus operations. On March 16, 2020, Job
         Corps issued Program Information Notice (PIN) 19-14 establishing a
         spring break and temporarily closing centers from March 16, 2020,
         through April 14, 2020. In consideration of federal, state and local

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         guidelines, including the existence of at least 44 state shelter-in-place
         orders, Job Corps extended its break through May 10, 2020 via follow-up
         PIN 19-15 issued on April 13, 2020. On May 11, 2020, Job Corps
         transitioned to remote learning and kept center campuses closed.

     •   Transporting students to their homes or finding alternative living
         arrangements. According to Job Corps, centers provided students with
         transportation home and to their designated alternative locations, or
         worked with local authorities to find other arrangements, and continued
         providing housing and food to students who remained on campuses due
         to students who had no stable and safe alternative housing arrangements.

     •   Ensuring safety and health of students still at centers. Job Corps told us
         445 students remained on its campuses. To minimize the risk of an
         outbreak on a center, Job Corps said it worked with medical consultants to
         assess the medical risks associated with consolidating the remaining
         students at one of six proposed centers (one center in each region) and
         settled on a much smaller scale consolidation of students to ensure
         student safety. As of May 31, 2020, 55 centers remained open to house
         and feed students who had no stable and safe alternative housing
         arrangements. Job Corps also allowed staff to work on centers to clean
         and sanitize the facilities. To protect everyone still on campus, Job Corps
         issued standard operating procedures (SOPs) on April 3, 2020, outlining
         reporting and notification responsibilities when a center staff member or
         student tests positive for COVID-19. Job Corps also issued PINs and INs
         providing centers with the CDC’s COVID-19 environmental cleaning and
         disinfection recommendations to use in cleaning and sanitizing Job Corps
         facilities (April 8, 2020) and a checklist to help them determine what
         actions to take upon being informed of a staff or student who tests positive
         for COVID-19 (April 21, 2020).

  Job Corps informed us that between March 16 and May 31, 2020, 4 students and
  35 staff on center campuses tested positive for COVID-19 (as of May 31, 2020).
  According to the noted checklist and other Job Corps guidance, centers’ actions
  include the following:

     •   Notify Job Corps’ management, its Health and Wellness Manager,
         contracted regional health specialists (as needed), and the local health
         department of the positive test and follow directions about any needed
         actions;

     •   Identify the students and staff the person who tested positive may have
         interacted with during the previous 14 days, provide this information to Job



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         Corps and the local health department, and follow directions about any
         needed actions;

     •   Implement temperature check plan and other precautionary measures
         consistent with CDC guidance;

     •   Isolate students who test positive for COVID-19 or have symptoms, while
         ensuring staff have the necessary Personal Protective Equipment (PPE)
         to safely manage them;

     •   Alert all students and staff about of positive cases while maintaining
         privacy;

     •   Monitor the health of students in isolation, as well as students and staff at
         and off center; and

     •   Clean and disinfect all heavily impacted work areas using a professional
         company, in addition to their routine cleaning and disinfecting.

  Additionally, Job Corps needs to continue monitoring the number of individuals
  testing positive, provide oversight to ensure the appropriate actions are
  completed and take any necessary steps to contain the spread of COVID-19 at
  its centers.

  Students in Need of Prescription Medication

  Providing prescription medications to students after Job Corps suspended on
  campus operations was another challenge. Students have access to basic
  medical services on center, including prescription medications when students are
  leaving campus on planned breaks. Because campus operations were
  suspended, access to prescription medications was limited.

  To address this, Job Corps issued PIN 19-16, on April 24, 2020, requiring
  centers provide access to prescription medication to students while they are off-
  center during the duration of the break, including sending medication via mail in
  compliance with federal and state laws, as well as arranging transfers of
  prescriptions to local pharmacies or providers.




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  CONTINUING TO DELIVER TRAINING, CAREER
  TRANSITION, AND OUTREACH AND
  ADMISSIONS SERVICES


  To continue delivering academic and career instructional training, ETA
  transitioned all Job Corps centers to distance learning. Since most students are
  low income, high school dropouts and have deficiencies in basic skills, many
  students may not have the tools (e.g., laptop or internet service) or the ability to
  learn remotely without the structured environment Job Corps provides. Job Corps
  also started requiring its career transition and outreach and admissions services
  providers work remotely.

  Providing Learning Activities and Career Skills Training to Students

  Job Corps temporarily transitioned all centers to virtual training to ensure
  students continue to receive training during the pandemic. However, virtual
  training will be a challenge for Job Corps’ student population. Many students are
  high school dropouts and/or basic skills-deficient (i.e., have reading, writing, and
  computer skills at or below the 8th grade level). Without the structured
  environment Job Corps provides, which includes housing, food, and healthcare,
  as well as guidelines for going to bed and getting up early, some students may
  not be able to learn remotely and may leave the program. However, Job Corps
  has stated these students will have the flexibility to return to the program once
  centers resume on campus operations.

  Furthermore, like many school districts nationwide, Job Corps did not have an
  established infrastructure in place to deliver its entire training program virtually.
  Job Corps is creating the needed infrastructure by requiring center operators to
  design and deploy distance-learning plans that are consistent with contract
  requirements and program guidance. To accomplish this, Job Corps took, or is
  taking, the following actions:

     •   On April 24, 2020, Job Corps issued PIN 19-17 requiring centers to
         transition to virtual training starting on May 11, 2020. According to Job
         Corps, centers can deliver remote training through online courses, mobile
         learning, webcasts, podcasts, video learning, computer-based instructions
         and other tools. According to Job Corps, as of July 15, 2020, almost
         19,000 active students have logged onto Google Classrooms, the largest
         online platform being utilized for distance learning by Job Corps centers.

     •   PIN-19-17 also requires center operators and national training contractors
         to provide telework or distance learning plans for trades that may typically
         require equipment or hands-on-instruction. This will be especially


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         challenging as some technical training skills that require hands-on
         demonstration of technical proficiency, such as automotive and machine
         repair, carpentry, and advanced cement masonry, may be difficult to learn
         when limited to only virtual instruction.

     •   Provided national training contractors and centers templates to support
         tracking and reporting student attendance and participation.

     •   Job Corps will continue to use its self-paced training methods and address
         individual training needs as needed. When requested, Job Corps will work
         with students with disabilities to determine reasonable accommodations.

     •   Required centers to provide students an alternative to learning online that
         included using learning packages that are mailed to students.

     •   Shared contractor common practices in distance learning to support
         collaboration and drive continuous improvement in the delivery of
         services.

     •   On April 22, 2020, Job Corps conducted an information technology survey
         of 29,055 active students. Of the 25,357 students who responded, 85
         percent reported having access to either a computer, laptop, or smart
         device to be able to access an online distance learning platform, indicating
         at least 3,800 students did not have access to either of these. Job Corps
         is working to ensure each student has the needed tools — a laptop or
         tablet and internet service — for remote learning by August 2020. Given
         Job Corps’ income eligibility requirement (i.e., receive public assistance
         and/or live below the poverty line), many students may not have the
         necessary equipment to learn remotely.

     •   Retained an educational consultant to review and advise Job Corps on
         improving its distance learning program.

  Reopening Centers

  Resuming operations at 121 center campuses brings more challenges, such as
  implementing physical distancing with large student bodies in classrooms,
  common areas, and dorms; obtaining sufficient supplies of PPE (e.g., facemasks,
  face shields, gloves), disinfectants, and cleaning products; and transporting
  students to centers.

  Job Corps told us it is currently developing criteria for contract operators to use in
  planning for resuming physical operations of centers when it is in the best
  interest of the health and safety of the students. These criteria will require

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  contract operators to follow CDC, federal, state, local and other guidelines when
  developing their center specific reopening plans. Job Corps will work with the
  centers to evaluate their preparedness to resume physical operations on a case-
  by-case basis taking all guidelines into consideration as well as the health and
  safety of students. The goal is to take the necessary steps to mitigate the
  possibility that a COVID-19 outbreak will occur at one of the centers. On
  April 29, 2020, as part of its planning for resumption of on-center operations in
  the future, Job Corps issued PIN 19-18 providing estimates for annual medical
  and oral health PPE needs for Job Corps health staff based on center size when
  undertaking pandemic planning, and providing routine medical and oral health
  services.

  Extending Students’ Time in Program

  Closing on-center operations for months may result in students leaving the
  program and not returning to centers when the residential program resumes.
  Even if they do return, Job Corps told us that some might have challenges
  resuming their trade and basic skills learning. Further, other students may
  surpass the allotted amount of time they may remain in the program (i.e., age
  out). 1

  To address this issue, Job Corps said it will grant extensions. To address the rest
  of the issues, Job Corps said it and center staff will continue to monitor and
  address the on-going needs of students as issues develop.

  According to Job Corps, students in Advanced Training (AT) programs may be
  unable to become proficient in any required hands-on training. These students are
  being disproportionately impacted as the Workforce Innovation and Opportunity Act
  (WIOA) limits them to a maximum of three years of enrollment. Pursuant to WIOA at
  29 U.S.C. § 3196(b)(4), Job Corps requested a 180-day extension of the
  enrollment limit for all students in AT programs. These enrollment extensions will
  enable Job Corps to mitigate the disproportionate negative impact of COVID-19
  to students in AT programs and ensure that Job Corps resources are not wasted
  in unnecessary separations of students who are unable to complete AT before
  they reach the enrollment limit.

  Recruiting New Students

  Shelter-in-place and stay-at-home orders and recommendations imposed by at
  least 44 states and many local governments may have a negative impact on Job
  Corps’ recruitment efforts. On April 24, 2020, Job Corps issued PIN 19-17 for

  1 Job Corps’ age range is 16-24 years old. According to Job Corps, its most successful students

  stay in the program at least 18 months.


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  contractors to resume outreach and admissions efforts virtually. This includes,
  but was not limited to, file reviews; virtual contact with prospects, applicants, and
  enrollees; outreach to community groups and organizations; and planning.

  Finding Jobs for Graduates

  Job Corps’ center operators and career transition services providers trying to find
  jobs for recent program graduates may face significant challenges due to a
  slowed economy resulting from the pandemic. Federal, state and local social
  distancing, and shelter-in-place and stay-at-home orders and recommendations
  temporarily shuttered businesses nationwide. According to DOL’s Bureau of
  Labor Statistics (BLS), the unemployment rate in April 2020 increased by 10.3
  percentage points to 14.7 percent — the highest rate and the largest over-the-
  month increase in the history of the data (available back to January 1948). On
  April 24, 2020, Job Corps issued PIN 19-17 for contractors to resume job
  placement services virtually.


                                   CONCLUSION


  The COVID-19 pandemic poses several challenges for Job Corps. Job Corps
  initiated a number of actions to mitigate health concerns and continue providing
  training, placement and outreach/admission services. These actions ranged from
  temporarily closing center campuses nationwide to deploying remote learning to
  nearly 30,000 students, and granting extensions to students who now need more
  time to complete their education and training. Still, other challenges remain, such
  as protecting the 445 students and essential staff who are still on center
  campuses. As of May 31, 2020, 4 students and 35 staff on centers tested
  positive for COVID-19. Job Corps also needs to ensure centers are properly
  prepared to reopen their campuses considering prevention guidelines for
  physical distancing, cleaning and disinfecting, and health monitoring, plus having
  an adequate stock of cleaning supplies and PPE. Job Corps faces more
  challenges with remote learning as many students do not have laptops or tablets,
  or even internet access, and need extra resources, equipment (e.g., power tools
  for carpentry trades), and hands-on instruction to learn. To address these
  challenges, OIG makes recommendations related to protecting the health of
  students and staff at centers and learning remotely.




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                         OIG’S RECOMMENDATIONS


  The OIG recommends the Assistant Secretary for Employment and Training
  require the following:

     1. To safeguard the health of students and staff still at centers, Job Corps
        should continue to follow CDC, state, local and Job Corps’ COVID-19
        prevention and mitigation guidance.

     2. Job Corps should continue monitoring the number of individuals testing
        positive, provide oversight to ensure the appropriate actions are
        completed, and take any necessary steps to contain the spread of COVID-
        19 at its centers.

     3. Job Corps should ensure centers provide needed resources to address
        the learning needs of all students, including students who require
        reasonable accommodations, hands-on-instruction, and special equipment
        to learn.

     4. Job Corps should develop a plan to help ensure all students still at centers
        and learning remotely have the necessary resources (e.g., laptops, paper
        packets) to continue to receive training while center campuses remain
        closed.

     5. Prior to reopening campuses, Job Corps should ensure all centers have
        proper controls in place to adhere to federal, state, local and other
        guidelines – from physical distancing to having ample disinfectant,
        cleaning and PPE supplies.




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  SUMMARY OF ETA’S RESPONSE

  The Assistant Secretary for Employment and Training generally agreed with our
  recommendations and said ETA has implemented and continues to implement
  the majority of them as the COVID-19 pandemic continues. ETA’s written
  response to our draft report is included in its entirety in Appendix B.


  We appreciate the cooperation and courtesies ETA extended us during this audit.
  OIG personnel who made major contributions to this report are listed in
  Appendix C.




  Elliot P. Lewis
  Assistant Inspector General for Audit




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          APPENDIX A: SCOPE, METHODOLOGY, & CRITERIA


  SCOPE

  This audit covered ETA’s initial actions to address the risks and challenges
  presented by the COVID-19 pandemic as they relate to the Job Corps program.

  METHODOLOGY

  We conducted this performance audit in accordance with generally accepted
  government auditing standards. Those standards require that we plan and
  perform the audit to obtain sufficient, appropriate evidence to provide a
  reasonable basis for our findings and conclusions based on our audit objective.
  We believe that the evidence obtained provides a reasonable basis for our
  findings and conclusions based on our audit objective.

  To answer our audit objective, we relied on INs, PINs, and press releases
  publicly available on Job Corps’ website, interviews with ETA and Job Corps
  officials knowledgeable about the information and written responses to questions
  from ETA and Job Corps officials. We determined the information was sufficiently
  reliable for the purposes of this report.

  Furthermore, we:

     •   Reviewed Job Corps’ website, policies and procedures, and reports to
         obtain a general understanding of program operations.

     •   Reviewed prior OIG and GAO audit reports for issues related to our audit
         objective.

     •   Reviewed CDC guidance related to prevention, cleaning and disinfecting,
         schools, shared housing, and workplaces.

     •   Reviewed federal, state, and local government websites, as well as media
         reports, for COVID-19 data, stay-at-home and shelter-in-place orders, and
         other prevention guidance.

     •   Reviewed BLS’ national unemployment data for our scope.

     •   Interviewed ETA and Job Corps’ headquarter officials to obtain their input
         on challenges created by the COVID-19 pandemic on center operations,


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         as well as the actions ETA took to address them. We also sent detailed
         questions to ETA to get similar, but in-depth information.

     •   Reviewed national guidance related to the mitigation of COVID-19 within
         learning and shared living quarters’ environments.

     •   Reviewed press releases, INs, and PINs Job Corps issued from March
         through May 2020 to determine the actions Job Corps took to address the
         various challenges caused by the COVID-19 outbreak.

  Internal Controls

  In planning and performing our audit, we considered Job Corps’ internal controls
  relevant to our audit objective by obtaining an understanding of those controls,
  and assessing control risks relevant to our objective. We considered the internal
  control elements of control environment, risk assessment, control activities,
  information and communication, and monitoring during our planning and
  substantive phases and evaluated relevant controls. The objective of our audit
  was not to provide assurance of the internal controls; therefore, we did not
  express an opinion on Job Corps’ internal controls. Our consideration of internal
  controls for administering the accountability of the program would not necessarily
  disclose all matters that might be significant deficiencies. Because of the inherent
  limitations on internal controls, or misstatements, noncompliance may occur and
  not be detected.

  Criteria

     •   Workforce Investment Act (1998), which was superseded by the
         Workforce Innovation and Opportunity Act (2014)
     •   Job Corps’ INs 19-08, 19-09, and 19-12
     •   Job Corps’ PINs 19-14, 19-15, 19-16, 19-17, and 19-18
     •   CDC Interim Guidance for Businesses and Employers to Plan and
         Respond to Coronavirus Disease 2019 (COVID-19)
     •   Occupational Safety and Health Administration Guidance on Preparing
         Workplaces for COVID-19 (OSHA 3990-03 2020)
     •   National Strategy for Pandemic Influenza (Homeland Security Council,
         November 2005)
     •   Updated Preparedness and Response Framework for Influenza
         Pandemics (CDC 9/26/2014)
     •   CDC Interim Guidance for General Population Disaster Shelters During
         the COVID-19 Pandemic (5/14/2020)
     •   CDC Guidance on Considerations for School Closures (4/27/2020)



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     •   CDC Interim Guidance for Administrators of US K-12 Schools and Child
         Care Programs (3/18/2020)
     •   CDC Interim Guidance for Administrators of US Institutions of Higher
         Education (3/17/2020)
     •   CDC Interim Guidance on Unsheltered Homelessness and Coronavirus
         Disease 2019 (COVID-19) for Homeless Service Providers and Local
         Officials (5/12/2020)
     •   CDC Interim U.S. Guidance for Risk Assessment and Work Restrictions
         for Healthcare Personnel with Potential Exposure to COVID-19
         (5/10/2020)
     •   CDC Guidance for Reopening Buildings After Prolonged Shutdown or
         Reduced Operation (5/7/2020)
     •   CDC/EPA guidance for cleaning and disinfecting public spaces,
         workplaces, businesses, schools and homes (4/28/2020)
     •   CDC Considerations for Schools (5/19/2020)
     •   CDC Guidance – Prevent Getting Sick (COVID-19)




COVID-19: ETA SHOULD CONTINUE TO CLOSELY MONITOR IMPACT ON JOB CORPS
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                            U.S. Department of Labor – Office of Inspector General


       APPENDIX B: AGENCY’S RESPONSE TO THE REPORT




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COVID-19: ETA SHOULD CONTINUE TO CLOSELY MONITOR IMPACT ON JOB CORPS
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                            U.S. Department of Labor – Office of Inspector General




COVID-19: ETA SHOULD CONTINUE TO CLOSELY MONITOR IMPACT ON JOB CORPS
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                                 U.S. Department of Labor – Office of Inspector General


                   APPENDIX C: ACKNOWLEDGEMENTS


  Key contributors to this report were:

  Nicholas Christopher (Audit Director)
  Jon Ling (Audit Manager)
  Fernando M. Paredes (Audit Manager)




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REPORT FRAUD, WASTE, OR ABUSE
 TO THE DEPARTMENT OF LABOR




               Online
  http://www.oig.dol.gov/hotline.htm

             Telephone
  (800) 347-3756 or (202) 693-6999

                 Fax
           (202) 693-7020

               Address
     Office of Inspector General
      U.S. Department of Labor
    200 Constitution Avenue, NW
            Room S-5506
       Washington, DC 20210


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