Revised data validation deadlines and source documentation
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This is Change 1 to TEGL 3-03. The complete official packet also includes Attachment A: Source Documentation Requirements, transcribed below.
EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM
U.S. DEPARTMENT OF LABOR
Washington, D.C. 20210
CLASSIFICATION: Data Validation
CORRESPONDENCE SYMBOL: PRO
DATE: August 20, 2004
TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 3-03, Change 1
TO: ALL STATE WORKFORCE AGENCIES; ALL STATE WORKFORCE LIAISONS
FROM: EMILY STOVER DeROCCO, Assistant Secretary
SUBJECT: Data Validation Policy for Employment and Training Programs
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Purpose. To provide revisions and clarifications to policy guidance previously issued to states and national program grantees concerning the Employment and Training Administration’s data validation policy, for the following programs: Workforce Investment Act (WIA) Title IB, Wagner-Peyser Act / Employment Service (ES), Trade Adjustment Assistance (TAA), National Farmworker Jobs Program (NFJP), Indian and Native American (INA) Program and Senior Community Service Employment Program (SCSEP).
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References. Training and Employment Notice (TEN) No. 14-02, “Data Validation Initiative;” TEN No. 8-02, “Implementation of Common Performance Measures for Job Training and Employment Programs;” and President’s Management Agenda (http://www.whitehouse.gov/omb/budget/fy2002/mgmt.pdf).
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Background. In TEGL No. 3-03, the Department issued policy guidance to states and national program grantees on the timeframes for implementing data validation requirements on program performance reports. This change outlines revisions to those implementation timeframes and updates information given on data validation software. TEGL No. 3-03 provided exceptions for certain verified report deadlines which do not apply to Program Year (PY) 2003 annual reports. For PY 2003, report validation must be completed prior to submission of the annual report in accordance with the timetables specified below.
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Implementation for State Programs. Reporting instructions for data validation for state programs will be issued separately in a revised handbook on the Performance Web site at http://www.doleta.gov/performance/. The timeframes for implementation are as follows:
RESCISSIONS: [none listed]
EXPIRATION DATE: Continuing
Workforce Investment Act Title IB. For PY 2003, each state is required to submit a validated annual report by October 1, 2004, and the appropriate WIA Standardized Record Data (WIASRD) records by October 15, 2004. States will be required to complete report validation prior to submitting the annual report (ETA 9091), and data element validation using a file of exiters and participants reported on the ETA 9091 by February 1, 2005. This date reflects a change from last year’s timetable. Data element validation is now due 120 days after the submission of the annual report, not the submission of the WIASRD records.
Employment Service. Each state is required to submit the ETA 9002 and VETS 200 reports on a quarterly basis, 45 days after the end of the report quarter. The ES requires report validation and minimal data element validation. Report validation must be conducted for the ETA 9002 and VETS 200 reports due on November 15, 2004, prior to submission. A minimal data element validation sample of 25 job seekers must be reviewed and compared to state-level data prior to submitting the ETA 9002 and VETS 200 reports, to ensure that the files used to conduct report validation were properly constructed. States that use the ETA provided software or DART software to prepare their ETA 9002 and VETS 200 quarterly reports do not need to conduct separate report validation.
Trade Adjustment Assistance. Each state is required to submit its fourth quarter file Trade Act Participant Report (TAPR) for Fiscal Year (FY) 2004 by November 15, 2004. For TAA, ETA only requires the submission of individual participant records, and not a report containing aggregate performance information; thus, states are not required to conduct report validation. States are required to conduct data element validation on the cumulative file of four quarters of the FY 2004 TAPR (created by adding the four quarterly files together). The data element validation for TAA must be completed by February 1, 2005.
- Implementation for National Programs. Reporting instructions for data validation for national grant programs will be issued separately. The timeframes for implementation are as follows:
National Farmworker Jobs Program. The NFJP grantees are not required to submit an annual report but are required to submit individual participant records; therefore, they are not required to conduct report validation. Instructions and training will be provided in November 2004. The final NFJP participant data for Program Year 2003 is due February 15, 2005. Data element validation for PY03 must be completed by June 15, 2005.
Indian and Native American Program. Grantees are required to submit their annual ETA 9084 Comprehensive Services Report by September 30 (90 days after the June 30th program year end date). Validation software for INA programs is still in development. Instructions, training, and timetables for data validation will be issued at a later date.
Senior Community Service Employment Program. The SCSEP is creating a new report and a new reporting system. The first SCSEP “annual report” will not be produced until fall 2005. Data validation instructions, training, and timetables will be issued at a later date for this program.
- Data Validation Tools. ETA has developed instructional handbooks, standardized software, and user guides that states and grantees can use to perform data validation.
• Handbooks provide detailed information on the validation methodology, including sampling specifications and data element validation instructions for each data element to be validated. ETA is providing guidance detailing required source documents to validate eligibility, services, and outcomes. States and grantees should be prepared to start collecting and storing appropriate source documents for all current activities effective immediately. A list of approved source documents for each element is provided in Attachment A. States and grantees will not be required to obtain source documentation for activities that occurred prior to the issuance of this guidance.
• Version 3.0 of the data validation software will be released in August 2004. The updated version will be available in time for states and grantees to use it to validate the annual reports due by October 1, 2004.
• User guides developed for each ETA validation software application guide states and grantees through the process of installing the application, building and loading a validation file, and completing report and data element validation.
ETA’s validation handbooks, software applications, and user guides for each program can be found on ETA’s Web site at http://www.doleta.gov/performance/. Click on the link for Reporting Guidance and Data Evaluation and go to the third bullet point, Data Validation and more. The validation tools for the WIA Title IB, ES, and TAA programs are currently available and reflect the reduction in data elements; tools for the national grant programs will be posted when finalized.
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Training and Technical Assistance. States and grantees are encouraged to request technical assistance on validation procedures and the use of the validation tools by contacting regional staff. To avoid unnecessary delays and problems in the implementation of data validation, regional staff is available to facilitate the validation process and to address any difficulties states and grantees encounter. E-mail and phone contact information is available on the ETA Web site listed above, in the Help menu of each software application, and in the user guides.
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Monitoring. To ensure that states and grantees are able to successfully complete validation procedures and standards, ETA will monitor the validation effort on a regular schedule. The record retention requirement that will apply to records of all validation activities, including files, worksheets, reports, and source documentation, is three years.
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Action Required. States and grantees are expected to:
• Distribute this advisory to the appropriate program staff.
• Notify the appropriate regional office or the Office of National Programs if they intend to use a methodology to perform data validation other than the methodology developed by ETA. States interested in alternative methodology for validation of WIA Title IB, ES, or TAA programs should notify the appropriate regional office by September 15, 2004.
• Complete data validation within the timeframes established in Section 5 of this guidance and provide the appropriate regional office with an update on the validation process.
- Inquiries. Questions regarding the data validation initiative should be directed to the appropriate regional office or to the Office of National Programs, as appropriate.
Attachment A: Source Documentation Requirements
Attachment A: Source Documentation Requirements
ATTACHMENT A: SOURCE DOCUMENTATION
Revised Elements for Data Validation & Source Documentation Requirements
For WIA Programs
This list is intended to provide guidance to states and grantees regarding what types of source
documentation are acceptable to validate certain components of eligibility, services and
outcomes as required on the reports. Please note:
• Only one document listed is required for each element. For example, for element
#101 Individual Identifier, clients only need to present one of the listed
documents such as a DD-214 or a passport or a Social Security card.
• Documentation is only required for clients who receive more than core services.
Clients who enroll in training or other intensive services must provide the
required source documents for validation purposes.
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
Individual Yes Yes Yes Yes Social Security Card
Identifier DD-214
#101 Passport
1
Database Assigned number
from the state management
information system
Date of Birth Yes Yes Yes Yes Copy of I.D., Baptismal
#102 record, birth certificate, DD-
214, Report of Transfer or
Discharge paper, driver’s
license, Federal, state or local
identification card, passport,
2 hospital record of birth, public
assistance/social service
records, school records or ID
cards, work permit, cross
match with Department of
Vital Statistics, tribal records
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
Individual with a Yes Yes Yes Yes Letter from Drug or Alcohol
Disability rehabilitation agency, medical
#104 records, case notes regarding
observable conditions,
physician’s statement,
psychologist’s diagnosis,
rehabilitation evaluation,
Social Security
Administration records,
3
school records, sheltered
workshop certification, social
service records or referrals,
disability records, Veteran’s
medical records, vocational
rehabilitation letter, worker’s
compensation record, self
attestation
Veteran’s Status Yes Yes Yes No DD-214, cross match with
4
#111 veterans data
Employment Yes No Yes Yes Pay stub, case notes showing
Status at information collected from
5
Registration registrant
#115
U.I. No Yes No No UI cross-match, UI notice of
Compensation entitlement
6
Programs
#118
Low Income Yes No Yes Yes Alimony Agreement,
#119 applicant statement, award
letter from veteran’s
administration, bank
statements, compensation
award letter, court award
letter, pension statement,
employer statement/contact,
family or business financial
7 records, housing authority
verification, pay stubs,
pension statement, social
security benefits, public
assistance records, quarterly
estimated tax for self-
employed persons, Social
Security benefits, UI
documents
TANF Yes Yes Yes Yes Cross match with TANF
8 #120 public assistance records
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
General Yes Yes Yes Yes Copy of authorization to
Assistance receive cash public assistance,
#121 copy of public assistance
check, medical card showing
9
cash grant status, public
assistance, refugee assistance
records, cross match with
public assistance database
Displaced No Yes No No Public assistance records,
Homemaker court records, divorce papers,
10 #124 bank records, spouse’s layoff
notice, spouse’s death record,
self attestation
Date of Actual No Yes No No Verification from employer,
Qualifying rapid response list, notice of
11 dislocation layoff, public announcement
#125 with follow-up cross-match
with UI, self attestation
Homeless No No Yes Yes Written statements from an
individual and/or individual providing
runaway youth residence, shelter or social
12
#126 service agency, WIA
registration form, self
attestation
Offender No No Yes Yes Documentation from juvenile
#127 or adult criminal justice
system, documentation phone
13 call with court
representatives, WIA
registration form, self
attestation
Pregnant or No No Yes Yes Copy of child’s birth
parenting youth certificate, baptismal record,
14 #128 observation, doctor’s note
confirming pregnancy, self
attestation
Youth who needs No No Yes Yes See state policy and state
additional plan, individual service
15 assistance strategy, case notes, WIA
#129 registration form, state MIS,
self attestation
Education status No No Yes Yes Applicable records from
at time of education institution (GED
registration certificate, diploma,
#130 attendance record, transcripts,
16
drop out letter, school
documentation), WIA
registration form, State MIS,
self attestation
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
Basic literacy No No Yes Yes Standardized assessment test,
skills deficiency school records, case notes
17 (as defined in
664.205)
#131
Date of WIA Yes Yes Yes Yes Date of application and
registration Title signature, date signed WIA
18
1-B status form, state MIS
#302 information
Date of WIA Yes Yes Yes Yes WIA status/exit forms, state
19 Exit MIS data, Case notes
#303
Supportive No No Yes Yes Case notes
20 Services
#330
Date of first Yes Yes No No Cross match between dates of
intensive service service and vendor training
#332 information, vendor training
21
documentation, state MIS,
case notes
Date of first Yes Yes No No Cross match between dates of
training service service and vendor training
#333 information, vendor training
22
documentation, state MIS,
case notes
Established ITA Yes Yes No No Check ITA account activity,
23 #334 Asset database, State MIS,
case notes
Adult education, Yes Yes No No Vendor training
basic skills documentation, certificates,
24 and/or literacy state MIS data, case notes
activity
#335
On-the-job Yes Yes No No Vendor training
training documentation, OJT master
25
#336 contract, state MIS data, case
notes
Occupational Yes Yes No No Vendor training
skills training or documentation, credentials,
skills upgrading/ state MIS documents, school
26 retraining and/or records, diploma, case notes
workplace
training
#337
Educational No No Yes Yes Activity sheets, sign-in sheets,
achievement attendance record, vendor
27
services contract, state MIS, case notes
#340
Employment No No Yes Yes Activity sheets, vendor
28 services contract, attendance rosters,
#341 state MIS, case notes
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
Received No No Yes Yes Activity sheets, work
summer youth agreement, sign-in sheets,
29 employment attendance roster, state MIS
opportunities system, case notes
#342
Additional No No Yes Yes Activity sheets, pay stub,
support for youth sign-in sheets, attendance
30
services rosters, state MIS, vendor
#343 contract, case notes
Leadership No No Yes Yes Activity sheets, vendor
development contract, attendance roster,
31
opportunities state MIS, case notes
#344
Received follow- No No Yes Yes Activity sheets, attendance
up services rosters, receipt for follow-up
32
#345 support services, state MIS,
case notes
Post Program Yes Yes Yes No UI Wage records, WRIS,
Employment supplemental data sources
33 #601 defined by TEGL 7-99
State management
information system
Source of Yes Yes Yes No Follow up services, surveys,
Supplemental record sharing and/or
Data automated record matching
34 #602 with other employment and
administrative databases,
other out of state wage record
systems, case notes
Entered training Yes Yes No No Employer contacts, state MIS,
related WIA exit or status form, cross
35 employment match between occupational
#605 training code and occupation
code
Employed in Yes Yes Yes No UI wage records, WRIS,
third quarter supplemental data sources as
36
after exit defined in TEGL 7-99
#608
Source of Yes Yes Yes No Follow-up services, surveys,
supplemental record sharing and/or
data automated record matching
37 #609 with other employment and
administrative databases,
other out of state wage record
systems, case notes
Third quarter Yes Yes Yes No UI wage records, WRIS, other
prior to state wage records, federal
38
registration wage databases
#612
Third quarter No Yes No No UI wage records, WRIS, other
prior to state wage records, federal
39
dislocation wage databases
#613
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
Second quarter Yes Yes Yes No UI wage records, WRIS, other
prior to state wage records, federal
40
registration wage databases
#614
Second quarter No Yes No No UI wage records, WRIS, other
prior to state wage records, federal
41
dislocation wage databases
#615
First quarter Yes Yes Yes No UI wage records, WRIS, other
following the state wage records, federal
42
exit quarter wage databases
#616
Second quarter Yes Yes Yes No UI wage records, WRIS, other
following the state wage records, federal
43
exit wage databases
#617
Third quarter Yes Yes Yes No UI wage records, WRIS, other
following the state wage records, federal
44
exit quarter wage databases
#618
Type of Yes Yes Yes No Transcripts, certificates,
recognized diploma, surveys, case notes
educational/
occupational
45
certificate/credential/diploma/
degree attained
#621
Other reasons for Yes Yes Yes Yes State MIS, waiver form,
exit doctor’s records, hospital
46 #622 records, contact with the
penal system, case notes
In post- No No Yes No Record sharing with state
secondary board of governing
education or community colleges, state
advanced board of governing
training gin universities, state education
47 quarter after exit associations, integrated post
#623 secondary education reporting
unit, higher education
planning unit, training
certificates, diploma, survey
enrollment form, case notes
DATA ADULT DISLOCATED OLDER YOUNGER Source Documentation
ELEMENT WORKER YOUTH YOUTH Requirements
In post- No No Yes No Record sharing with state
secondary board of governing
education or community colleges, state
advanced board of governing
training in the universities, state education
48 third quarter associations, integrated post
after exit secondary education reporting
#624 unit, higher education
planning unit, training
certificates, diploma, survey
enrollment form, case notes
Skill attainment No No No Yes Test Records, Transcripts,
goals School/Employer
49 Elements Notification, State MIS, Case
#625-672 notes
Attained No No No Yes Transcripts, diploma, notice
secondary school from school
50
diploma
#673
Date of High No No No Yes Transcripts, diploma, notice
School diploma from school
51
or GED
#674
Youth placement No No No Yes Cross match with other
and retention agencies, apprenticeship
information verification, military service,
#675 & 676 advanced training, post
secondary education,
52
transcripts, registration forms,
comm.college info, employer
contacts, U.I. wage records,
WRIS, Case notes
Revised Elements for NFJP Data Validation & Source Documentation Requirements
DATA ELEMENT Source Documentation
Requirements
Date of Enrollment IEP Certification, self attestation, case manager/counselor
1
#004 intake application with signature
Date of Birth Copy of I.D., Baptismal record, birth certificate, driver’s
#005 license, Federal, state or local identification card, passport,
hospital record of birth, public assistance/social service
2
records, school records or ID cards, work permit, cross
match with Department of Vital Statistics, tribal records
Qualifies for Sec. 167 Program as a Farmworker Pay stubs, W-2 forms, IRS 1040 forms, case
3 or dependent or spouse of a Farmworker manager/counselor intake notes, self attestation
#009
DATA ELEMENT Source Documentation
Requirements
Farmworker Status Pay stubs, W-2 forms, IRS 1040 forms, case
4
#011 manager/counselor intake notes, self attestation
Number of individuals in the Family Birth certificate, family bible, IRS 1040 forms
5
#013 b
Total Preprogram earnings during the 12-Month Pay stubs, W-2 forms, employer payroll records, IRS 1040
6 eligibility determination period forms, Administrative wage records
#017
Long-term Agricultural employment IRS 1040 forms, pay stubs, intake application, case
7 #020 f manager/counselor progress notes, self-attestation
Date of First Intensive Services Case manager/counselor progress notes with signature, IEP
8
#024 assessment and diagnostic testing
Date of First Training Service Case manager/counselor certification signature, employer
9 #025 signed document, attendance records from institution or
instructor
Enrolled in a program or activity leading to an Case manager/counselor progress notes with signature;
10 educational or occupational credential or license employer signed document; attendance records from
#028 institution or instructor; intake application
Date of Exit Case manager/counselor termination notice; case
11
#035 manager/counselor progress tracking report
Category of Exit Grantee Administrative Records
12
#036
Other reasons for Exit Grantee Administrative Records
13
#037
Date Entered Unsubsidized Employment Case manager/counselor progress notes; letter from
14
#038 employer
Attainment of state recognized educational or Copy of diploma/degree; record from Department of
occupational certificate, credential, diploma or Education; school sign-in sheet and certification completed
15
degree by instructor
#042
Total earnings during 6 months since placement Pay stubs; employer payroll records; IRS tax forms,
16 #044 a administrative/UI wage records, case manager/counselor
progress notes with signature
Has participant been employed at any time during Pay stubs, employer payroll records, IRS 1040 forms, case
17 the 4th, 5th or 6th months after placement? manager/counselor progress notes, self attestation
#044 b
Revised Elements for Trade Data Validation & Source Documentation Requirements
DATA ELEMENT Source Documentation
Requirements
Veteran Status DD-214, cross match with Veterans Data, cross match with
1
I.8 Wagner-Peyser State MIS
Most Recent Qualifying Separation Layoff or rapid response list, determination of eligibility,
2 I.13 notice of termination, letter from employer
Date of Application Application in case file, State MIS, WIA registration form,
3
I.15 Designation of Eligibility form
DATA ELEMENT Source Documentation
Requirements
Petition Number Worker group certification in case file, State MIS, UI
4 I.16 records, DOLETA website, Determination of Eligibility
form
Date Entered Training Vendor training documentation in case file, case notes,
5 II.1a State MIS, attendance lists, UI records, WIA status forms
Date completed, or withdrew from, training Vendor training documentation in case file, WIA status
6 II.1b form, training plan
Training Completed Vendor training documentation in case file, WIA status
7 II.1c form, state MIS, case notes about communications with
program, applicant statement, UI records
Trade Readjustment Allowance (TAA) State UI records of TRA checks issued, request for
8
II.2 allowance, state MIS
Waiver from training requirement Case file documentation that includes initial approval and
9 II.3 renewals at 30 day intervals, State UI records of TRA
checks issued, form from employment counselor
Date of Exit Documentation in case file, State MIS, WIA exit form
10
III.1
Employed in first full quarter after exit UI Wage records, WRIS, supplemental data sources as
11
III.2 defined in TEGL 7-99, state MIS
Employed in third full quarter after exit UI Wage records, WRIS, supplemental data sources as
12
III.5 defined in TEGL 7-99, state MIS
Three quarters prior to most recent qualifying UI Wage records, WRIS, other state wage records, Federal
13 separation Wages Database
III.6
Two quarters prior to most recent qualifying UI Wage records, WRIS, other state wage records, Federal
14 separation Wages Database
III.7
First quarter following exit UI Wage records, WRIS, other state wage records, Federal
15
III.8 Wages Database
Second quarter following exit UI Wage records, WRIS, other state wage records, Federal
16
III.9 Wages Database
Third quarter following exit UI Wage records, WRIS, other state wage records, Federal
17
III.10 Wages Database
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