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 be assessed in the CY 2017 Assessments based on level of risk for non-compliance. The RAI factors in the date the CAC opened, the last date that it was assessed, whether there has been a change in the PIECP manager position for that particular CH, and other factors such as offender inquiry letters. Based on the RAI, NCIA selected 17 CHs to be assessed to include 51 CACs. Of the 17 CHs to be assessed, 15 will be site assessments and two will be desk assessments.
NCIA updated the assessment instruments for the CY 2017 PIECP assessments and forwarded them to BJA for approval. This included incorporating new policies and/or procedures from 'lessons learned' in the CY 2016 assessment round for both the PIECP Assessment Workbook and the PIECP Assessment Guide as well as assessor checklists and other instruments/tools. NCIA set up the training webinar for all PIECP Certificate Holders as well as the separate webinar for PIECP Assessors (both to be held in July).
NCIA generated two sets of notification letters for the PIECP 2017 Assessments. The first notification letters were sent to commissioners/secretaries/directors of corrections notifying them as to whether their agency had been scheduled for a PIECP assessment in 2017. The second set of notification letters is sent only to those jurisdictions who have been identified for an assessment--the letter is sent to the PIECP Managers advising them of the specific 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 sent out, NCIA's grant assistant entered all of the assessment information for each certificate holder into the PIECP database.
NCIA prepared the materials and PPT presentation for the 2017 PIECP Assessment Training Webinar and forwarded it to BJA during this reporting period. NCIA emailed invitations to all certificate holders and conducted the webinar on July 12, 2017. There were 47 participants in the PIECP Training Webinar. Julius Dupree of BJA co-presented with NCIA's Grant Manager. The post-training survey results showed 22 survey respondents, with 11 rating the webinar as excellent and 11 rating the webinar as satisfactory. All 22 respondents indicated they learned new information and took away specific action items that they would use in the management of their PIECP Program.
During the months of October through November 2017, NCIA assessors conducted site assessments of PIECP operations at 50 Cost Accounting Centers at 17 different PIECP Certificate Holders. This included pre-assessment work (reviewing payrolls and other necessary pre-work) prior to the visit, traveling to the site and conducting the assessment themselves. Included in the assessment is observing the inmate work operation, interviewing offenders, reviewing payrolls, reviewing voluntary forms on file at the location and other mandatory criteria requirements per the PIECP statute. All assessments were completed in this timeframe. Following the site visits, assessors are responsible for writing their assessment reports and providing that draft report to the Certificate Holder within 30 days of the site visit. Certificate Holders then have 30 days to respond to compliance items included in the assessment report. From there, the report can be finalized. As of this writing, eight site assessment reports have been finalized with the remainder in draft report status. These should be completed no later than April 1, 2018
While the actual 2017 assessments took place in October through December of 2017, the majority of Certificate Holders assessed had compliance issues. Assessors and ultimately NCIA's Grant Manager continued to work throughout the first six months of 2018 to bring each of these PIECP Certificate Holders into compliance. This involved NCIA's Grant Manager working with BJA's PIECP Manager to review and resolve the various compliance issues with BJA's approval. It often included the payment of back wages to inmate workers by the Certificate Holder which requires a tremendous amount of payroll review work by the NCIA Grant Manager. As of June 30, 2018, all assessment compliance work has been completed with the exception of four issues that have been referred to BJA for their policy approval. A 2017-2018 Assessment Summary Report will be submitted to accompany this TTA report on GMS.
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Please submit a signed letter of support from your agency’s executive or other senior staff member. The letter can be emailed to or uploaded with this request. The letter should be submitted on official letterhead and include the following information:
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