General Program Management  Policies and procedures
Memorandum #01-10

To:  All Subrecipients

Subject:  Corrective Action

Effective Date: July 1, 2001

A. POLICY

Snohomish County Workforce Development Council (WDC) monitoring reports or other administrative activity which identify a compliance exception, administrative issue, negative observation, or non-performance under the Workforce Investment Act, associated regulations, State provisions, local policy, the Strategic or Operations Plan, or the organization's subcontract shall require a written corrective action plan. This plan shall describe the problem, the corrective action to be taken, proposed implementation and completion dates, and possible consequences.

Failure to comply or perform within the timeframes established may result in a reduction, cancellation, or termination of the subrecipient's subcontract.

The WDC may, at its sole discretion and determination, reject a corrective action plan for lack of sufficient efficacy in resolution of an identified issue.

B. DEFINITIONS

    1. Compliance Exception

A compliance exception is any exception to the Workforce Investment Act, associated regulations, State provisions, or local policy that creates a risk to the resources or services of the program.

    2. Administrative Issue

An administrative issue is a condition or weakness which causes a circumstance or situation that presents a risk to the resources or services of the program.

    3. Negative Observation 

A negative observation is a local condition which presents a potential weakness in regard to the risk of the program's resources or services.

    4. Non-Performance

Non-performance is a local condition which results from the subrecipient not attaining program outcomes as specified in the subcontract.


C. PROCEDURES

    1. Compliance Exception, Administrative Issue, or Negative Observation

In the event that a subrecipient fails to comply with any Federal, State, or local WIA rule or regulation or has an administrative issue or negative observation, the WDC may elect to permit the submission of a corrective action plan. Effective completion of the action must occur within a period of time acceptable to the WDC given the severity of the issue.

    2. Non-Performance

In the event that a subrecipient fails to perform in accordance with its subcontract, the subrecipient may be required to submit a written corrective action plan within the timeframe allowed by the WDC.

    3. Record Retention Requirements

Written record of each corrective action requested and submitted will be retained in the subrecipient's subcontract file at the WDC.