NCIA conducts site and desk compliance assessments of PIECP Cost Accounting Centers (CACs) to assure BJA that the PIECP Certificate Holders are operating within the proegrams statutory and administrative requirements. This process includes the following: 1) updating the compliance assessment materials to reflect current BJA policy; 2) evaluating the risk assessment instrument to determine high, medium and low risk program compliance for selection of CACs to be assessed in the current round; 3) notifying Certificate Holders of the upcoming assessment; 4) selecting consultant assessors from the field; 5) conducting assessment training webinar to all certificate holders; 6) conducting assessor training; 7) coordinating all assessments via the assessors; 8) reporting all compliance issues to BJA along with recommended compliance plans; 9) working with the certificate holder to bring them into compliance; and 10) finalize the assessment reports including a final summary report to BJA.
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NCIA analyzed the activity of all PIECP Certificate Holders (CHs) and their Cost Accounting Centers (CACs) and, using the Risk Assessment Instrument (RAI), determined which CACs should e assessed in the CY 2018-2019 assessments based on level of risk for non-compliance. The RAI factors in the date the CAC opened, the last date it was assessed, whether there has been a change in the PIECP manager position for that particular CH, and other factors such as allegations of non-compliance or offender inquirity letters. NCIA selected 17 CHss to be assessed to include 59 CACs. Fifteen assessments will be site assessments and two will be desk assessments (with no travel). If NCIA learns of any non-compliance during the grant period, additional desk assessments (or even site assessments) at the direction of BJA will also be completed.
NCIA updated the assessment instruments for the 2018-2019 PIECP Assessments and forwarded them to the BJA PIECP Program Manager for Approval. This included incorporating new policies and/or procedures from lessons learned in the 2017 PIECP Assessments for both the PIECP Assessment Workbook and the PIECP Assessment Guide as well as assessor checklists and other instruments/tools. NCIA then updated the PPT training materials for the PIECP Assessment Training Webinar and the Assessor Training Webinar to align with these updates to the guide and workbook.
NCIA generated two sets of notification letters for the 2018-2019 PIECP Assessments. THe first notification letters were sent to commissioners/secretaries/directors of corrections notifying them as to whether their DOC or agency had been scheduled for a PIECP assessment in 2019. These went out on October 15, 2018. The second set of notification letters is sent only to those jurisdictions who have been identified for an assessment--the letter was mailed on December 3, 2018 to the PIECP Manager advising them of the specific cost accounting centers (CACs) that will be assessed , the timeline for the assessment, and instructing them on the materials they are required to submit to NCIA prior to the site assessment itself. Prior to these notification letters being mailed, NCIA's grant assistant entered all of the assessment information for each certificate holder into the PIECP database.
At the direction of BJA's PIECP Program Manager, NCIA's Grant Manager and Technical Consultant traveled in October of 2018 to conduct an ad-hoc assessment of a certificate holder who had multiple allegations by inmate workers that one of their PIECP Cost Accounting Centers (CACs) was out of compliance. This was a large CAC of more than 100 inmate workers. The grant manager and technical consultant assessed this CAC in detail, interviewing three times the number of inmates that is required in a normal assessment (normally 10% of the workforce) and studied the inmate payrolls in detail to assure compliance.
This assessment report is still being finalized.
During this reporting period, NCIA's grant manager continued to work with four certificate holders who were found out of compliance in their 2017 PIECP assessments. This is because often times, it takes certificate holders months to calculate the back wages due to inmate workers or change a DOC policy administratively or for other reasons. NCIA worked with one certificate holder from 2017 through the end of July 2018 to finalize the multiple compliance issues and complex back wages. Additionally, the grant manager finalized two of the other three compliance plans, with just one still outstanding. This work entails dozens of hours of analyzing back wages and other reports to ensure that the PIECP CACs are working in compliance with BJA guidelines.
During this reporting period, NCIA's Grant Manager conducted the PIECP Assessment Training Webinar and the Assessor Training Webinar. He, with the assistance of the grant assistant, coordinated all site logistics with assessors to include travel arrangements as well as receiving the appropriate wage and payroll documentation needed prior to the actual site visit itself. During the months of March through May 2019, PIECP assessors traveled to 15 Certificate Holders to conducted compliance site visits of 57 Cost Accounting Centers (CACs). Additionally, the senior technical consultant also conducted desk assessments of two Certificate Holders (1 CAC each), totalling 17 total PIECP Assessments consisting of 59 CACs for this grant reporting period. As of 6/30/19, all assessment reports have been drafted by the PIECP assessors and are in various phases of being finalized, depending on the need for compliance plans. The goal is to finalize all reporting by 9/30/19 and provide BJA with the 2019 Summary of Assessment Findings at that time.
During this reporting period, assessors worked with the 17 PIECP Certificate Holders to finalize their assessment reports--this includes furnishing the draft assessment report to the certificate holder with compliance recommendations and the certificate holder agreeing to the findings. It then includes working with the certificate holder to resolve the issues that are preventing them from achieving a compliance finding. These issues may include back wages to be paid to inmate workers, voluntary forms being revised, and other significant issues. As of this writing, NCIA is still working with 3 certificate holders to bring them into compliance--two for back wages owed and one for an updated involuntary form. All other 2019 PIECP assessments have been closed with full compliance obtained.
A 2019 Assessment Summary Report will be appended to this semi-annual report submission.
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