Focus on Governance Updates in Regulatory and Compliance. Presenter: Chris Wilkie, AVP Regulatory, Oversight, & Monitoring

Transcription

1 Focus on Governance Updates in Regulatory and Compliance Presenter: Chris Wilkie, AVP Regulatory, Oversight, & Monitoring

2 Crystal Balls VS. Easter Eggs Crystal Balls Gypsy Fortune-teller Magical Powers Predictions of the Future Easter Eggs Mini Hidden Treasures Excitement of the Unknown Surprises (Rewards) 2

3 Easter Eggs Every Time - Hands Down Easter Eggs and Mission Treasures = People We Serve Excitement = Mission Fulfillment Surprises (Awards) = Jobs Created Easter Eggs, the Hunt, and Compliance/Regulatory Piece to the Puzzle, Part of a Bigger Story Well-coordinated and Integrated Collection of ALL Capabilities Elimination of Silos Between Major Players 3

4 What is the Connection? 4

5 Disney s List of Easter Eggs for its Films 5

6 Importance of Regulatory & Compliance Regulatory and compliance should be a well-coordinated and integrated collection of your NPA s processes and capacities Break-down silos between the major players and departments (or actors) across your NPA When not connected there can be trouble and inefficiencies Silos equal counter-productive objectives, sub-optimal strategies, and performance that is not optimized 6

7 Recap FY16 Year-End Easter Egg Treasures Cooperative Agreement, Regulatory Implications Reporting Requirements, NPA Implications FY16 Year-End Data 7

8 Cooperative Agreement The CNA shall monitor, report, and assist NPAs in maintaining qualifications in accordance with 41 CFR The CNA shall provide training to NPAs regarding meeting regulatory requirements within the JWOD Act, 41 U.S.C. Chapter 85 and implementing regulations, 41 CFR Chapter 51. The CNA shall develop a qualified NPA oversight protocol and deliver it to the Commission for review and approval within 120 days after execution of the agreement. (PWS ) 8

9 Reporting Requirements Commission Policy , NPAs Out of Compliance with Commission Regulations High Risk = An NPA that is out of compliance for multiple, major reasons or has a direct labor ratio below 60 percent At Risk = An NPA that has a direct labor ratio below 75 percent or one that is out of compliance for a single reason CNA recommendations and Commission actions 9

10 FY16 Results No/Late FY16 Reps & Certs 37 total NPAs (33 late submissions, 4 submission at all) Results = 4 Show Cause Letters from the Commission Below 75% Agency Ratio 19 total NPAs (2 with Commission approved exemptions) Results = FY17 Probation Period and Presentation to Commission Members (multi-year non-compliance) 10

11 FY16 Q1 Results Direct Labor FY15 FY16 % Change Products $5,213,259 $5,220, % Services $36,099,755 $36,247, % Total $41,313,014 $41,468, % Wages FY15 FY16 % Change Products $39,743,968 $41,040, % Services $489,224,001 $509,453, % Total $528,967,969 $550,494, % Hourly Wage FY15 FY16 % Change Products $7.26 $ % Services $13.55 $ % Total $21.18 $ % 11

12 FY16 Results Workforce FY15 FY16 % Change Products 8,051 7, % Services 35,056 34, % Total 43,107 41, % Promotions FY15 FY16 % Change Supervisor % Non-Sup , % Total 1,250 1, % Placements FY15 FY16 % Change AbilityOne 1,950 2, % All - Total 23,445 24, % 12

13 Results & Deficiencies FY16 Medical Documentation IEE Forms Drug-Free Workplace SCA Affirmative Action / Form I-9 FY17, Q1 Placement Programs (Tied for 5 th with Form I-9) 13

14 Focus on the Future 14

15 Compliance & Regulatory Reviews NPA Oversight Protocol = 35 Compliance Topics Training Announcements Coming Summer 2017 Annual Reps/Certs QER Reporting CNA Fee Phase-In Plans Surges Support Service Agreements Change in Legal Status Delinquent Federal Taxes Criminal and/or Civil Charges Debarment, suspensions, or ineligible for contract award Direct Labor Hour Records and Ratios (Agency and AbilityOne) Disability/Medical Documentation Competitive Employment Reports (IEE) AbilityOne Project Ratios IRS Form I-9 Availability of Records On-going Placement Programs Promotion of PWSD Contract Performance Issues DOL investigations Fair Labor Standards Act (FLSA) Executive Order # c Certificate Prevailing Wages Piece Rates Hourly Commensurate Rates Service Contract Act (SCA) Davis Bacon Act 1931 (DBA) Affirmative Action OSHA Veterans Employment Report (VETS-4212) Drug Free Workplace Red Font = Most Common Deficiencies Employer Information Report (EEO-1 Report) Family Medical Leave Act (FMLA) Contractor Code of Business Ethics and Conduct 15

16 Compliance & Corrective Action Plans Assigned Corrective Action Plans 30 or 60 days to Complete Report CAP to Commission Complete, Not Complete, Non-Responsive At Risk or High Risk of being found out of compliance Dedicated personnel monitoring and tracking CAPs Situations Not Complete or Non-Responsive, SourceAmerica will recommend formal corrective action by Commission, aligned with Commission Policy

17 Compliance Resources for NPAs (Assistance) 17

18 Compliance Resources for NPAs (Training) 18

19 Extranet Demonstration SourceAmerica Extranet 19

20 Compliance Training for NPAs 2017 (remaining) Scheduled Regulatory Trainings Federal Compliance 101 May Honolulu, Hawaii July Chicago, Illinois November 8-9 Dallas, Texas Time Studies with Productivity Enhancement May Honolulu, Hawaii June 7-8 Albany, New York August Minneapolis, Minnesota December 6-7 Tampa, Florida SourceAmerica Academy 20

21 Compliance Training for NPAs Compliance Cornerstones: A series of six webinars focused on the U.S. AbilityOne Program Compliance requirements. 1. June 15 U.S. AbilityOne Program and ROM overview 2. June 22 AbilityOne definitions and employee classifications 3. June 29 - Medical Documentation 4. July 13 Individual Eligibility Evaluation 5. August 3 Regulatory Reviews, QER, and Reps/Certs 6. August 10 - Maintaining compliance/resources/assistance 21

22 Closing Thoughts Value of life is relationship. We love those we serve and we all love mission. Compliance is about choices, protection and guarding our treasures. 22

23 Surveys Time to Give Your Feedback! We are going Green this year! To access the survey, log into the app, click on the session The survey link will be located at the top of the session description Thank you for participating! 23