i/ olici~ - nvworkforceconnections.org .pdf · 1: u1·/i/ nr·l'( 0\1 ec'llo ·s • j j...

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1:·urk./(,,,.,.L, CO'.\ N ECTl<Y\S I '' j Workforce Connections General Policies ADW-030-04 Data Recording and Management October 2013 Policy Approved By: WC Executive Director \ \ \ Ll P olicy Ado pted on: Augu st 01 , 2013 I/ Purpose: fo i dult and Dislocated Worker To establish Workforce Connections' (WC) ro ram: p p g Data Collection and Management Background: As written in [20 CFR §667.300 (a) and (b)], all States and other direct grant recipients must report financial, participant, and performance data in accordance with instructions issued by the Department of Labor (DOL). Workforce Connections is required to establish basic standard operating procedures for data collection and management to ensure the quality and integrity of the collected data over time. Service Providers currently under contract with Workforce Connections and receiving WIA Title I formula funds shall follow this policy. Service Providers may establish written internal procedures that meet the requirements of this policy. Policy: Workforce Connections has established that for the purpose of Federal, State and local reporting requirements, all data related to WIA registration and services provided to eligible WIA Title I program participants must be recorded in WC MIS-NVTRAC within eight (8) business days of the occurrence of such events and/or activities. Workforce Connections requires timely written notification if required data entry cannot be accomplished within the required time frame. This policy applies to all Workforce Connections' Service Providers providing WIA Title I services to Adult and Dislocated Workers. Reference: Workforce Investment Act (WIA) [Section 136 (d) (2)] [20 CFR §667.300] [WIA State Compliance Policy 5.5] A. Required Accurate and timely data entry is essential for the reliability and quality of reported WIA Title I services, activities, and performance outcomes. This includes standards for data verification, data validation, and data security. B. All information required by Federal, State, and local reporting requirements must be collected for each individual receiving service under a WIA Title I funded program. The appropriateness of any service provided to an eligible program participant should be documented in the individual employment plan and should show a clear linkage between the provided service and potential improvement in the participant's employability or career objective goals. M Cl) 0... orkforce Connections Policy ADW-030-04 Adult & Dislocated Worker Program Workforce Connections is an equal opportunity employer/program.

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Page 1: I/ olici~ - nvworkforceconnections.org .pdf · 1: u1·/i/ nr·l'( 0\1 EC'llO ·s • J J .i 'II ' D. Eligibility Addendum-1 Continuation 1. Grant services and activities must be documented

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Workforce Connections General Policies ADW-030-04 Data Recording and Management

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~evis~ October 2013

Policy Approved By: WC Executive Director ~ \ \ \ Ll

Policy Adopted on: Augus t 01, 2013 I/

Purpose: olici~ foi dult and Dislocated Worker To establish Workforce Connections' (WC) ro ram: p p g Data Collection and Management

Background: As written in [20 CFR §667.300 (a) and (b)], all States and other direct grant recipients must report financial, participant, and performance data in accordance with instructions issued by the Department of Labor (DOL). Workforce Connections is required to establish basic standard operating procedures for data collection and management to ensure the quality and integrity of the collected data over time. Service Providers currently under contract with Workforce Connections and receiving WIA Title I formula funds shall follow this policy. Service Providers may establish written internal procedures that meet the requirements of this policy.

Policy: Workforce Connections has established that for the purpose of Federal, State and local reporting requirements, all data related to WIA registration and services provided to eligible WIA Title I program participants must be recorded in WC MIS-NVTRAC within eight (8) business days of the occurrence of such events and/or activities. Workforce Connections requires timely written notification if required data entry cannot be accomplished within the required time frame. This policy applies to all Workforce Connections' Service Providers providing WIA Title I services to Adult and Dislocated Workers.

Reference: Workforce Investment Act (WIA) [Section 136 (d) (2)] [20 CFR §667.300] [WIA State Compliance Policy 5.5]

A. Required Accurate and timely data entry is essential for the reliability and quality of reported WIA Title I services, activities, and performance outcomes. This includes standards for data verification, data validation, and data security.

B. All information required by Federal, State, and local reporting requirements must be collected for each individual receiving service under a WIA Title I funded program. The appropriateness of any service provided to an eligible program participant should be documented in the individual employment plan and should show a clear linkage between the provided service and potential improvement in the participant's employability or career objective goals. M

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orkforce Connections Policy ADW-030-04 Adult & Dislocated Worker Progra m Workforce Connections is an equal opportunity employer/program.

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Addendum-1

I. General Provisions for Data Collection Requirements

A. Data Verification

1. Data verification is a process that involves checking the accuracy of all, or a sample of, computerized records against the original paperwork or other source(s).

2. Although the goal of data entry is to achieve 100 percent correct entries, it is rarely accomplished due to recording of typing errors. Overall data verification process is the confirmation of the accuracy of all, or a sample of, typed/recorded entries by comparison with the original source(s) to identify and properly correct errors.

B. Data Validation

1. Data validation involves checking the reasonableness of all, or a sample of, data recorded or entered into an electronic database.

2. Although data may be correctly transcribed from forms, it may not be accurate or logical because of recording errors. For example, entering a wrong date of birth raises concerns about the accuracy of such entries, regardless of whether or not they were properly transcribed from the paperwork or other sources.

C. Data Security

1. Data security involves ensuring only authorized staff has access to electronic databases and paper files containing sensitive program participants' information. It is imperative that personal information be protected at all times.

2. Program Participants' information can only be released to third party agencies or entities if the program participant has authorized such release or the custodian of the records is presented with a valid court order requesting information pursuant to legal action.

D. A procedure for data collection and management to ensure the resulting electronic database is accurate, includes but is not limited to the following:

1. Checking the accuracy of the computerized records against the original source (usually paper copies ofrecords);

2. Conducting random calls to program participants or other sources to verify the accuracy of the information collected;

3. Ensuring case files containing program participants' information are secured in filing cabinets and access to such files is limited to authorized personnel only;

4. Evaluating data collection efforts by using trained staff to randomly observe interviews and other data collection methods;

5. Limiting access to program participants' information to authorized personnel who are trained in data security and validity and have acknowledged in writing the requirement to safeguard program participants' data; and

6. Performing logical tests of data (although data may be correctly transcribed from the original forms, it may not be accurate because of misprints and other mistakes).

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II. Data Requirements

Addendum-1 Continuation

A. Workforce Connections Management Information System (MIS) - NVTRAC Currently required data processing; collection; reporting; and case management system.

1. An applicant is an individual for whom eligibility determination has been made. An individual must be informed that it is necessary to provide eligibility documentation when applying for WIA Title I services.

2. The application process may not be completed until eligibility documentation is received. In general WIA Title I funded program reports shall contain information such as the following:

a) Application b) Eligibility determination c) Participation d) Outcomes e) Case notes

B. Workforce Connections MIS-NVTRAC manual is the recommended reference tool for standard data elements that must be collected and maintained. The WC MIS-NVTRAC manual can be located at below link:

http :ljwww. nvwo rkfo rcecon nections.org/Ad min/a ttach/NVtrac%20M an ua I without%20forms. pdf

a The Management Information System MIS-NVTRAC is the standardized data processing collection and reporting system for Workforce Connections. Service Providers(s) and/or contractor(s) are responsible for the integrity and validity of recorded data which is required to be complete and without error.

C. The application 1. Has been designed to collect all data necessary to meet Federal, State and local

requirements and to determine applicant eligibility. Once an applicant is determined to be eligible for WIA Title I services, the eligibility determination form must be properly completed. A signed printout eligibility determination form from NVTRAC becomes part of the program participant's file and is subject to document retention requirements. The applicant is required to sign and date the eligibility determination form certifying the accuracy of the information and the understanding that falsification may result in immediate termination from the program and penalties as specified by law.

2. Verification of eligibility is used to ensure the appropriateness of provision of services and to guarantee that services are provided to persons most in need.

3. The primary responsibility for collecting source support documentation rests with the WIA Title I program staff in charge of processing determination of eligibility. Copies of all documentary evidence and/ or source support documentation must be maintained in the program participant's file and is subject to retention requirements ..

I Workforce Connections Policy ADW-030-04 I I Adult & Dislocated Worker Program Workforce Connections is an equal opportunity employer/program.

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D. Eligibility

Addendum-1 Continuation

1. Grant services and activities must be documented during the intake or enrollment process. Intake refers to the process of gathering information and assessing an individual's appropriateness for a given set of services or activities. In the context of establishing participant eligibility, verification means to confirm whether individuals meet certain requirements based on an examination of official documents (e.g., birth certificate, public assistance records, etc.). Documentation means to maintain in-file physical evidence, which is obtained during the verification process, that an individual is eligible for participation in a WIA Title I funded program or project. Source support documentation can be obtained from participants, partner organizations, employers or through electronics systems. Such source support documentation must become part of the program participant's file.

2. Table 1 provides an example of acceptable source documentation Service Providers can use to verify information collected during the intake process. The information and documents used to verify eligibility will differ substantially for each case since they are evaluated or assessed on an individual basis. Please keep in mind the examples listed below are not inclusive of all the available sources of information. Rather the table is provided as an illustration of the type of documents that Service Providers can use. For more information concerning acceptable source support documentation, please see WC - Policy ADW-030-05 table A, Record Retention.

Table - 1 Acceptable Source Support Documentation Examples of Common Data Elements or

Elifilbili Criteria Birth Date/ Age

U. . Work Authorization: Service Providers may require that participant has a legal right to work in the U.S. For up-to-date information

I Qfi the U.S.C.I.S ._.Pleast~ .. _gp_t~.USCiS .gOV

I Selective Service Registration: Male registrant 18 years of age or older born on or after January 01, 1960 must present evidence that

I he has complied with Section 3 of the Military Selective Service Act. Note: Must take into consideration TEGL 11-11

change 1 and 2 Reside in Geographic Area:

,.._--~~~~~~~~~~~~~~~~

Examples of Acceptable Documentation

D Birth certificate D Baptismal or church record D Driver license D Federal, State, or local government -

issued identification card D Verification of document(s) that satisfy

list A of the I-9 form D Verification of document(s) that satisfy

li~t B ancl_ C of th~ 1-:-9 fo!'I11 D Printout of the Selective Service

verification registration internet: www.sss.gov

D Selective Service registration card D SSR verification (form 3-A) D Form DD-214 D Self statement D Valid Nevada State driver license D Valid Nevada State picture ID D Utility bill or federal correspondence

showing name on paper and current known address

I Workforce Connections Policy ADW-030-04 I I Adult & Dislocated Worker Program

Workforce Connections is an equal opportunity employer/program.

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E. Participation:

Addendum-1 Continuation

1. For the purpose of this guidance, participation occurs following the determination of eligibility and commences when the individual begins receiving a service funded by the WIA Title I program. This phrase has the same meaning as the "date of participation" used in some common measures. Program performance measures are keyed to the participation cycle. Therefore, accurate documentation and timely data collection of enrollment, as well as provided services and follow up services into the WC MIS-NVTRAC system, is critical.

2. The participation date is the date an eligible applicant receives the first participation service and is enrolled as a program participant. A participation service is a WIA Title I program funded service provided to an eligible applicant. Included are core staff assisted services, intensive services, and training services.

3. A program participant is an eligible applicant who has received at least one participation service after the date the applicant was determined eligible. The term participation period refers to the duration of the participation cycle.

4. Service Provision: It is essential to the integrity of participant data that services entered into the record reflect services actually provided to the program participant and that all activities involving a program participant are correctly, timely identified and accurately recorded in the program participant's NVTRAC record. In addition, whether or not the service was anticipated in the Individual Employment Plan (IEP), there must be a clear indication in a case note that the service will aid in the attainment of a goal(s) or career objective(s) specified in the IEP. In other words, each participation service requires a case note that includes a full description and justification for the service provided.

5. Gap in Service: A gap in service prevents an unintended exit from occurring and may be utilized by the program staff in one of three allowable circumstances. The duration of the gap in services cannot exceed 30 days, and the program staff must document one of the following circumstances in addition to the participant's intent to continue services once the issue prompting the gap in service has been resolved:

a) Delay before the beginning of training; b) Health/medical condition or providing care for a family member with a

health/medical condition; and c) Temporary move from the area that results in temporary discontinuance of

services, including National Guard or other related military service.

6. Case notes must refer to physical support documentation as well as notes from the interview with the program participant specifying the reason for the gap and the program participant's intent to complete the service/program agreed-upon IEP. Program staff may approve continued suspension of services for an additional 30 days and only up to 90 days to address unforeseen circumstances that arise during the first gap in service. A program participant cannot exit prior to the actual end date of a gap in service. l.1j !

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F. Outcomes:

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Addendum-1 Continuation

1. [Section 136 (I), (II), and (III)] of the Workforce Investment Act (WIA) specifies core indicators for performance for workforce investment activities in adult, dislocated worker, and youth programs. As indicated in [Section 136 (a)] the purpose of this section is to establish a comprehensive performance accountability system, comprised of the activities described in this section, to assess the effectiveness of State and local areas in achieving continued improvement of workforce investment activities funded under this subtitle, in order to optimize the return on investment of Federal funds in Statewide and local workforce investment activities.

2. Table 2 provides an example of the services that are reflected in performance measures. The WIA performance measures, other than customer satisfaction measures, are applied separately to three (3) funding streams: adult; dislocated workers, and youth. ETA maintains that it is important to measure performance for each group. ETA also intends to promote greater accountability and reduce inconsistencies among the States in their performance computations. Only WIA adult and dislocated worker participants who receive services will be taken into account when computing WIA performance measures.

Table - 2 Examples of WIA services reflected in performance measures WIA Intensive Services WIA Training Services ----=---41 CJ Com.J.>_rehensive and s ecialized assessment CJ Occu ational skills training

CJ Development of individual employment CJ On-the-Job training Ian

CJ Group counseling

CJ Individual counseling and career planning

CJ Workplace training and cooperative education ro rams

CJ Private sector training programs CJ Customized training_programs -~--~

Common Measures At-A-Glance CJ Entered Employment ./ Of those who are not employed at

the date of participation: CJ # of participants who are employed

in the first quarter after the exit quarter

CJ Employment Retention ./ Of those who are employed in the first quarter after the exit quarter:

CJ # of participants who are employed in bQth the second and third

uarters after the exit uarter CJ Average Earnings ./ Of those participants who are

employed in the first, second, and third quarters after the exit quarter:

CJ Total earnings in the second plus the total earnings in the third quarter after the exit guarter

For more information on outcomes: WC MIS-NVTRAC manual can be located at below link: http://www. nvworkforcecon nections.o rg/Ad min/ attach/NVtrac%20Man ual without%20forms. pdf

Workforce Connections Policy ADW-030-04 Adult & Dislocated Worker Program Workforce Connections is an equal opporhmity employer/program.

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G. Case Notes:

Addendum-1 Continuation

1. The Workforce Investment Act (WIA), [Section 101 (5)] defines case management. The term "case management" means the provision of a client-centered approach in the delivery of services, designed: (A) to prepare and coordinate comprehensive employment plans, such as service strategies, for participants to ensure access to necessary workforce investment activities and supportive services, using, where feasible, computer-based technologies; and (B) to provide job and career counseling during program participation and after job placement.

2. Case notes refers to either paper or electronic statements by the case manager that identifies a program participant status for a specific element, the date on which the information was obtained, full description of activity/service, and the case manager who obtained the information.

3. The Individual Employment Plan (IEP) and case notes are intended to properly document the delivery of WIA Title I services to eligible program participants. Information contained in participant NVTRAC record case notes must be timely and accurately recorded and relevant to the participant's employability or career objective goals.

4. Case managers' efforts to contact a program participant to monitor progress towards the goals stated in his/her IEP must be timely and accurately made in participants' NVTRAC record- Case Notes. It is the responsibility of the case manager to ensure that at least twice monthly contact is made with the program participant to maintain the highest level of participant services. The content of case notes must include information that accurately describes all services provided and the individual's experiences in WIA Title I activities.

For more information on case notes: WC MIS-NVTRAC manual can be located at below link: http:Uwww.nvworkforceconnections.org/Admin/attach/NVtrac%20Manual without%20forms.pdf

a) Case Notes - Documentation - Record Keeping the linkage: 1) To demonstrate how the case record is used to provide program

accountability, as well as documenting program participant achievements; 2) To stress the importance of timely, concise, accurate, standardized records

and case notes; 3) To demonstrate that accurate record keeping supports the case manager in

objectively planning, implementing, and evaluating services for each program participant; and

4) To demonstrate accountability and transparency for the organization and the founder.

I Workforce Connections Policy ADW-030-04 j I Adult & Dislocated Worker Program Workforce Connections is an equal opportunity employer/program.

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Addendum-1 Continuation

b) Table 3 provides an example of best practices for improving services and performance. The information and documents used to report participants' activities will differ substantially for each case since they are evaluated or assessed on an individual basis. Please keep in mind the examples listed below are not inclusive of all the available allowable practices. Rather the table is provided as an illustration of some practices that service providers can implement or use.

Table - 3 Examples of best practices Case notes

Documentation must be

Record results from a face to face meeting or conversation or a significant event regarding the participant progress in the program:

D Description of the context D Purpose D Observations D Content 0 Outcome D Assessment of person or situation D Plan D Follow-u_P., when a licabl_e~~~

Document the link of successes or failures to the IEP

D Timely D Factual D Relevant CJ Concise

Standard Practices for Case Managers

0 Enter case notes in a timely manner, as close to the actual event as possible 0 Review all participant files at the end of each month to assure that at least one contact

was made and recorded with each program participant during the month a Set aside a specific time each week for data recording and record keeping

Note: 1. Source Support Documentation Whether electronic or paper, the purpose of source support documentation is to have an auditable trail that documents eligibility, services delivered and outcomes received. "It is about accountability."

Four (4) common types of source support documentation are:

D NVTRAC or management information system - MIS D Cross-match D Self-attestation D Case notes

I Workforce Connections Policy ADW-030-04 I Adult & Dislocated Worker Workforce Connections is an equal opportunity employer/program.

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III. Case Management

A. What is Case Management?

Addendum-1 Continuation

1. The term "case management" means provision of a client-centered approach in the delivery of services, designed: (A) to prepare and coordinate comprehensive employment plans, such as service strategies, for participants to ensure access to necessary workforce investment activities and supportive services, using, where feasible, computer-based technologies; and (B) to provide job and career counseling during program participation and after job placement. [PL 105-220 Sec. 101 (5)]

2. Case management services are to be made available to all participants enrolled in Workforce Investment Act Title I programs. Federal law identifies case management as follows:

a) Comprehensive and specialized assessment of skill levels and service needs through:

1) Diagnostic testing and use of other assessment tools; and

2) In-depth interviewing and evaluation to identify employment barriers and appropriate employment goals.

b) Development of an individual employment plan to identify employment goals and objectives, and appropriate services needed to achieve those goals and objectives.

c) Information on training available in local and regional areas, information on individual counseling to determine which training is suitable based on their identified needs, and information on how to access and apply for such training.

d) Short-term prevocational services, including development oflearning skills, communications skills, interviewing skills, punctuality, personal maintenance skills, and professional conduct to prepare participants for employment or training activities.

e) Individual career counseling, including job search and placement counseling, during the period in which the participant is receiving services, and after receiving services for purposes of job placement.

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Addendum-1 Continuation

f) Provision of employment statistics information, including the provision of accurate information relating to local, regional, and national labor market areas, including but not limited to:

1) Job vacancy listing in such labor areas;

2) Information on job skills necessary to obtain jobs indentified in job vacancy listings;

3) Information relating to local occupations that are in demand and earnings potential of such occupations; and

4) Skills requirements for local occupations

g) Information relating to the availability of supportive services as described in Workforce Connections Policy ADW-030-09.

B. Case Manager Responsibilities

In addition to the defined case management identified above, case managers are responsible for:

1. Determining eligibility criteria and suitability for enrollment in WIA Title I program/ activities;

2. Properly completing participant(s) intake/enrollment in WC MIS-NVTRAC system within the required timeline;

3. Providing testing of basic skills, comprehensive assessment and testing; 4. Developing and continually updating the Individual Employment Plan (IEP); 5. Determining if participant requests for training and supportive services are

reasonable, allowable, and appropriate; 6. Coordinating joint training plans and employment services as appropriate; 7. Monitoring the progress of program participants; 8. Recording all program activities, services, supportive services, outcomes, and

case notes in the WC MIS-NVTRAC system within the required timeline and as service/ contact occurs, reflecting any significant issues or changes;

9. Keeping and maintaining the participant file in order and with all required source support documentation to properly justify service provision, WC Policy ADW-030-05, Record Retention - Program Participant File;

10. Ensuring that program participants are properly assisted and provision of services is in alignment with high quality standards, and in accordance to developed IEP;

11. Ensuring that integrity and accountability standards prevail ; and 12. As changes or updates occur, print and file the program participation report and

the case notes report.

I Workforce Connections Policy ADW-030-04 I I Adult & Dislocated Worker Program Workforce Connections is an equal opportunity employer/program.

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IV. MIS - NVTRAC Authorization and Access

Addendum-1 Continuation

A. As indicated on Item II (A) of this policy Workforce Connections Management Information System (MIS) - NVfRAC is the currently required data processing, collection, reporting, and case management system.

B. Workforce Connections will authorize employees of contract services and/or service provider organizations and agencies to use the WIA case management and reporting system (NV-TRAC) based on their job-related need to access and input data into the system. User rights will be assigned by Workforce Connections through individual user accounts. All new users must successfully complete MIS NV-TRAC training prior to rights being assigned.

C. Requirements:

1. Successful completion of MIS NV-TRAC training is required for staff with job duties that require participant data input, eligibility determination, registration, services, outcomes and/or report review.

2. All staff at the Nevada JobConnect centers must also successfully complete and sign the State of Nevada's Department of Employment, Training and Rehabilitation individual access and confidentiality agreement.

3. Each user must have an e-mail account issued by the service provider/employer. Hotmail, Yahoo and other accounts of this nature are not acceptable.

4. Current, in-program participants are not eligible for NV-TRAC user accounts.

5. The training request will be originated from management staff or designee.

6. All granted access users must sign the NV-TRAC User Agreement.

D. Confidentiality Standards

1. All information contained in NV-TRAC is confidential and shall not be disclosed to any person or organization except those authorized by Workforce Connections.

2. All NV-TRAC users must comply with all applicable Federal and State privacy and confidentiality laws. Failure to comply with such laws may result in a criminal prosecution and/or civil sanctions. Training and Employment Guidance Letter -[TEGL No. 39-11].

3. For the purpose of collecting and using workforce system participants' social security number, all Service Providers are mandated to ensure that social security numbers will be maintained in a secure and confidential manner [TEGL No. 5-08].

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Addendum-1 Continuation

4. Access to NV-TRAC is granted only by Workforce Connections authorized representative. In the event a person with granted access to NV-TRAC terminates employment with a Service Provider; it is the responsibility of the Service Provider's management to immediately notify Workforce Connections.

5. Workforce Connections reserves the right to monitor activities related to the use of the MIS NV-TRAC without previous notice to data system users.

6. Access may be terminated at any time without previous notice. Any individual with granted access to the MIS NV-TRAC is responsible for full cooperation in the event of a necessary investigation concerning wrongful use and/or misappropriation of information.

7. User account request can be found at below link: http://www.nvworkforceconnections.org/pdfs/NVTrac-User-Account-Request.pdf

8. User Agreement can be found at below link: http://www.nvworkforceconnections.org/pdfs/NVTrac-User-Agreement.pdf

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