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Practicum on DATA VALIDATION. Overview. Background & Basics Federal Requirements Issues/Findings from Federal Reviews Exercise: DEV with WIA NEG Record. USDOL’s Data Validation (DV) Initiative.
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Overview • Background & Basics • Federal Requirements • Issues/Findings from Federal Reviews • Exercise: DEV with WIA NEG Record
USDOL’s Data Validation (DV) Initiative • To support President’s Management Agenda and respond to data quality issues cited by oversight agencies • DV Directives • Eight guidance letters/notices to date • Initial Guidance – TEN 14-02 (5/28/03) • TEGL 3-03 and related changes • Latest Guidance – TEN 9-06 (8/15/06) • All performance-related guidance at www.doleta.gov/performance
How Does Validation Work? • Two separate processes required to ensure performance data are reliable • Report Validation • Data Element Validation • Report Validation (RV) ensures performance calculations are accurate • Data Element Validation (DEV) ensures the data used in the calculations are accurate
Understanding the Distinction • SCENARIO • A State reports an Adult Entered Employment Rate of 78% based on a numerator of 975 and a denominator of 1250 • The EER calculation is based on percentage of adults not employed at participation who were employed in the 1st quarter after exit • Other operational parameters apply, such as Transitioning Service Members* are automatically considered not employed at participation and included in calculations *TSM – Within 12 months of separation or 24 months of retirement
Data Quality from Perspective of RV • For instance, • How do we know the 78% is correct? Does the denominator consist of the “right” exiters (e.g., those not employed at participation)? Are all TSMs included in calculations as required? • In other words, are the calculations correct; did the State follow federal reporting specifications correctly?
Data Quality from Perspective of DEV • For instance, • How do we know those individuals identified as TSMs were actually within 12 months of separation or 24 months of retirement from the service? • For those “employed in the 1st quarter after exit,” what if the exit date was actually in a prior quarter? • In other words, were the data used to generate the calculations correct to begin with?
The Bottom Line • Are the calculations reported by the State accurate based on federal reporting specifications? • Are the data used in the calculations accurate? • It’s all about Data Quality ! RV DEV
Federal Requirements • Report Validation • Programs that submit “year-end” aggregate reports must validate their reports prior to submission • WIA, Wagner-Peyser, VETS (not Trade) • RV is largely a technical function, performed at state level by IT staff • NOT the focus of this session • Data Element Validation • Pertains to ALL programs (but is minimal in case of LX) • Involves checking data in participant records against allowable source documentation to verify compliance with federal definitions • Elements “pass” or “fail” validation
More on DEV • ETA provides Data Reporting and Validation Software (DRVS), which generates a sample of participant records to be “inspected” by State staff • Except in the case of labor exchange programs (LX or Wagner-Peyser/VETS), DEV is very labor intensive because it involves state staff conducting reviews of a sample of participant records from across the state • Random sample for WIA and Trade • Typical sample for WIA might be ~1200 records • Typical sample for Trade might be ~150 records • 25 records for LX
More on DEV (cont’d) • For each participant record in the sample, a “DEV Worksheet” is generated that contains the elements selected for validation that apply to the specific participant • State Validators use the appropriate federal guidance (e.g., validation handbook) to note allowable source documentation and check the accuracy of each element • Documentation must either MATCH the element or SUPPORT the element • Most source documentation is located at the One-Stop level (wage record information stored at State level)
Summary • States are required to report accurate data and USDOL has oversight responsibility • USDOL requires RV and DEV (as applicable) and provides tools to assist, including software • Many states also use the software for reporting, although this isn’t required • User Guides and Handbooks for each program include allowable source documentation for critical data elements • Guidance states USDOL will monitor state DV efforts • This has begun!
Issues/Findings from Federal Reviews • What are some of the key macro-level issues affecting states’ ability to report accurate and consistent data? • What are some of the key micro-level issues affecting data quality as per federal reviews?
Macro-Level Issues Related to DV • Issues affecting State ability to collect and report accurate and consistent data • Flexibility in federal guidance (what, but not how) • Major changes to state management info systems (MIS) • Limited monitoring (state and federal) • Issues affecting State experience/compliance with DV • Identifying roles of different unit/staff (TAA in particular) • Communication of expectations and requirements to local areas • Lack of a comprehensive data management strategy (e.g., including monitoring of sub-grantees)
Data Element Validation Issues • Most Common DEV Issues • State failure to request or ensure complete case files • State staff not validating wage-related information as required • Changes to wage record data not documented • Incorrect, outdated or misapplied definitions of data elements (e.g., employment status at registration was used prior to PY05, incorrect capture of race and ethnicity) • Lack of MIS manuals or data collection guides to assist sub-grantees
Data Element Validation Issues (cont’d) • Lack of compliance with federal requirements pertaining to unique identifiers (particularly for those co-enrolled in TAA and WIA) • Quality of case notes varies dramatically • Incorrect and inconsistent dates within files (dates of participation, training, training completion, exit, date of birth) • Although Local (sub-grantee) staff have limited control over some areas, there is much that can be done locally to improve the structure and content of case files
Exercise • Experiencing DEV: • WIA NEG Case File • [Our thanks to the State of Tennessee]
“Setting Up” The Exercise • We are conducting PY05 DEV, using PY05 validation policies and instructions • What You Have: • Copy of WIA NEG case file with pages numbered (1-61) • DEV Worksheet • Source Documentation Instructions • For PY05 validation, instructions were part of TEN 9-06, dated 8/15/06 • PLEASE MAKE NO MARKS ON THE CASE FILE OR THE DOCUMENT CONTAINING SOURCE DOCUMENTATION; THESE MUST BE RETURNED AS IS • Only write on the DEV Worksheet
“Setting Up” the Exercise (cont’d) • About This File • eCase Management and Activity Tracking System or eCMATS is Tennessee’s MIS • Participant is female, single mother, under 30 • National Emergency Grant (NEG) received as result of permanent closure of facility in 2002 • Concurrent enrollment noted (TAA, W-P, Voc Ed., Rapid Response)
DEV Exercise • Elements to be Validated (exactly as appears on worksheet) • DislocationDate • ProgramParticipationDate • ProgramExitDate • NEGProject1 • FirstCoreServiceDate • FirstIntensiveService • DateEnterTraining • DateExitTraining • TrainingService1 • ExitEmployed1 • ExitEmployedMatch1 Note: Sometimes you need to “decipher” what the element means (e.g., “ExitEmployed1” actually means employment in first quarter after exit)
Data Element: Dislocation Date • Called “Date of Actual Qualifying Dislocation” in source documentation • The “value” is 12/06/2002 • Allowable source documentation • Verification from employer; rapid response list; notice of layoff; public announcement with follow-up cross-match with UI; self-attestation • Does it Pass or Fail and based on what?
Data Element: Program Participation Date • Called “Date of Program Participation” in source documentation • The “value” is 09/16/2003 • Allowable source documentation • State MIS Information • Does it Pass or Fail?
Data Element: Program Exit Date • Called “Date of Exit” in source documentation • The “value” is 09/30/2004 • Allowable source documentation • WIA status/exit forms, state MIS data, case notes • Does it Pass or Fail and based on what?
Data Element: NEG Project No. • Called “National Emergency Grant Project Numbers” in source documentation • The “value” is 0160 • Allowable source documentation: • Case notes or other file data specifying the particular layoff or emergency the precipitated enrollment. The project number for the grant(s) should be included. • Does it Pass or Fail?
Data Element: 1st Core Service Date • Called “Date of First Staff Assisted Core Service” in source documentation • The “value” is 09/16/2003 • Allowable source documentation • State MIS data • Does it Pass or Fail?
Data Element: 1st Intensive Service Date • The “value” is 09/16/2003 (same as 1st core service) • Allowable source documentation • State MIS data, case notes • Does it Pass or Fail and based on what?
Data Element: Date Entered Training • The “value” is 01/06/2004 • Allowable source documentation • Cross match between dates of service and vendor training information, vendor training documentation, state MIS, case notes • Does it Pass or Fail and based on what?
Data Element: Date Exited Training • Called “Date Completed or Withdrew from Training” in source documentation • The “value” is 03/29/2004 • Allowable source documentation • Cross match between dates of service and vendor training information, vendor training documentation, state MIS, case notes • Does it Pass or Fail and based on what?
Data Element: Type of Training Service • The “value” is 6 WIA reporting instructions contain codes • 1=OJT • 2=skill upgrading and retraining • 3=entrepreneurial training • 4=ABE or ESL in combination with training • 5=customized training • 6=other occupational skills training • Allowable source documentation • State MIS data, case notes • Does it Pass or Fail and based on what?
Data Element: Employed 1st Qtr After Exit • The worksheet refers to this element as “ExitEmployed1” and the source documentation refers to this as “Employed in 1st Quarter after Exit Quarter” • The “value” is 1, which means YES • Allowable source documentation • UI wage records, WRIS, supplemental data sources defined by TEGL17-05, State MIS • Does it Pass or Fail and based on what?
Data Element: Type of Employment Match • The worksheet refers to this as “ExitEmployedMatch1,” but the source documentation refers to this as “Type of Employment Match 1st Quarter After Exit Quarter” • The “value” is 1, which means “UI wage records and WRIS” • Allowable source documentation • Note: Follow up services, surveys, record sharing and/or automated record matching with other employment and administrative databases, other out of state wage record systems, case notes • Does it Pass or Fail and based on what?
Thank You! In God we trust. All others must use data. W. E. Deming