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's Grant Manager began the initial steps of the 2020 PIECP Assessments by reaching out to prospective assessors (both previous and new assessors-in-training) to notify them that PIECP assessors have been classified as sub-recipients of the PIECP award and as such, must sign a consultant assessor agreement containing new requirements as well as be monitored regularly by NCIA as the grant pass-through entity. NCIA developed a risk assessment tool and monitoring checklist as part of the assessor sub-recipient policy and process. NCIA distributed the new assessor agreements for signature and file.
NCIA's Grant Manager updated the assessment instruments for the 2020 PIECP assessments and forwarded them to BJA fo rapproval in preparation for the assessment cycle. He also updated the PIECP Training Webinar PPT and forwarded that as well to BJA for approval. NCIA's Grant Manager, along with BJA's PIECP Manager, conducted the Assessment Training Webinar for all PIECP Certificate Holders in March of 2020. As in the past, NCIA invites all PIECP Certificate Holders to participate in the webinar, even if they are not scheduled to be assessed, as it is an excellent training opportunity for new PIECP managers in particular and a refresher for all PIECP professionals. There were 55 PIECP participants on the Assessment Training Webinar. Following the Assessment Training Webinar, NCIA's Grant Manager conducted the Assessor Training Webinar (on all assessment processes and documents); nine assessors participated in the Assessor Training Webinar.
Using the Risk Assessment Instrument, NCIA's Grant Manager and Executive Director determined the PIECP Certificate Holders and Cost Accounting Centers (CAC)s that will receive a PIECP assessment during the 2020 round. NCIA's Grant Manager and Grant Assistant then prepared letters to DOC Commissioners to notify them of the impending assessment for their DOC. Following the notifications to DOC commissioners, NCIA's Grant Manager and Grant Assistant then prepare a second set of letters, specific to the PIECP Managers themselves. This letter advises them of the assessment training webinar in March of 2020 and instructs them as to the PIECP inmate payroll/assessment materials they must send to NCIA in advance of their assessment, due June 30, 2020. The assessor responsible for assessing the PIECP site is also copied on this correspondence. Upon the 6/30 deadline, NCIA collects the payroll documentation and other materials and forwards it to the assessor in preparation of the assessment.
NCIA's Grant Manager continued to work with five PIECP Certificate Holders on the following outstanding issues from the 2019 PIECP Assessments until they were completely resolved. (All issues were noted in the 2019 Assessment Summary Report submitted on 12/31/19.) This compliance technical assistance included verification of one certificate holder's back wage payments (for paying a wage below the 10th P wage requirement); resolution of two certificate holders' tardiness in submitting their annual wage updates during the required timeframe; and one certificate holder who did not move inmates up to the 10th P wage after completing the training wage period (required verification of back wage payments as well). As of this writing, there is one last PIECP certificate holder whose back wage payment verification is due to NCIA on 7/30; this will bring the 2019 PIECE assessments to closure with 100% compliance.
In total, there were thirteen wage issues. (Nine resolved; four pending back wage verification or review)
BJA's PIECP Policy Advisor advised NCIA that PIECP assessors would fall into the cateogry of sub-awardees for the PIECP Grant. NCIA's Grant Administrator then worked with the policy advisor on the drafting of all the required documents required for BJA sub-awards. BJA's PIECP Policy Advisor approved NCIA's sub-recipient policies and procedures in September of 2019. In January of 2020, NCIA's Grant Administrator notified all prospective PIECP assessors that they would need to comply with these new policies by signing the PIECP Consultant Assessor Agreement prior to being engaged as a PIECP assessor. NCIA then distributed and collected these signed forms. During this reporting period, NCIA's Grant Manager conducted regular monitoring of all consultant assessors, in compliance with NCIA's sub-recipient policies, including the completion of monitoring checklists of each assessor.
NCIA's Grant Manager prepared the PowerPoint presentation and conducted the 2020 PIECP Assessment Training Webinar and the Assessor Training Webinar. While only 20 PIECP jurisdictions are scheduled to be assessed in 2020, sixty-two registrants participated in the 2020 Assessment Training Webinar; many Certificate Holders use this webinar as an opportunity to also train new PIECP managers or as refresher training. There were also ten assessors on the PIECP Assessor Training. BJA's PIECP Program Manager was also a panelist on the Assessment Training Webinar.
The 2020 PIECP Assessments were scheduled to begin in July of 2020. When it became clear that the COVID-19 pandemic was not going away, and correctional institutions were not going to be allowing visitors into their prisons, NCIA made the recommendation to BJA's PIECP Program Manager to switch the 2020 PIECP Assessments from site assessments to desk assessments. PIECP desk assessments require the same information as a site, with the major drawbacks of not being able to observe inmates doing the work as described in PIE documents and not being able to interview those inmates. However, payroll/wage data and other mandatory criteria for PIECP programming can be assessed. As such, BJA approved converting the 2020 assessments to desk assessments and on July 22nd, NCIA's Grant Manager instructed the assessors to shift to desk assessments as the assessment vehicle and to begin their assessment work. Sixty Cost Accounting Centers (CACs) at 20 different PIECP jurisdictions were scheduled in this 2020 assessment cycle. As of the writing of this report, the assessment of 15 of the 20 PIECP Certificate Holders has been completed with full compliance. NCIA's Grant Manager and senior technical consultants are still working with the remaining five jurisdictions on compliance plans to bring their programs into compliance; we hope to achieve this before the grant closes on March 31, 2021. A full 2020 PIECP Assessment Summary report will be filed at that time.
As indicated in the previous milestone, NCIA's Grant Manager and senior technical consultants were still working with the remaining five jurisdictions on compliance plans to bring their programs into compliance as a result of the 2020 PIECP Assessments. As of 3/31/21, there were two remaining certificate holders who are still processing back wage payments to PIECP inmate workers. Once they are submitted, these last two certificate holders will be in compliance, bringing all certificate holders into 100% compliance through the 2020 PIECP Assessment Cycle. NCIA will work under the new PIECP Contract to ensure these back wage payments are executed. A full 2020 PIECP Assessment Summary report will be submitted to BJA's PIECP Program Manager as well as uploaded with the grant final reporting.
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