Compliance /Monitoring and Data Collection

Department of Labor and Industry

Office of Equal Opportunity

Purpose of Compliance Monitoring

• To ensure compliance with nondiscrimination and equal opportunity provisions of the Workforce Investment Act and Labor and Industry's EO Program.

• To identify needed changes to practices and policies as well as identification of staff and participant training needs.

• To check discrimination early, forestall complaints and correct violations promptly.

Federal Programs Unit• Conducts desk and on-site compliance reviews on

selected LWIAs, CareerLinks, UC Service Centers to ensure nondiscrimination in provision of services, admissions, placement, services to Limited English Proficient applicants/participants, clients and claimants.

• Develops, implements and monitors practices, policies and procedures necessary to ensure compliance with federal laws and regulations.

• Develops and facilitates equal opportunity training for LWIAs, CareerLinks and UC Service Centers.

• Ensures, through division staff, equitable delivery of services to customers, claimants, applicants and participants.

Federal Programs Unit• Conducts EO Compliance reviews in LWIAs to monitor

the provision of equitable services to eligible target groups.

• Develops mandated equal opportunity guidelines and coordinates the monitoring of civil rights compliance with federal laws and regulations.

• Develops and facilitates equal opportunity training for LWIAs, CareerLinks and UC Service Centers.

• Serves as liaison between the Department of Labor & Industry and the US Department of Labor, Civil Rights Center, and other federal and states agencies in matters pertaining to EO Compliance.

PennsylvaniaLocalWorkforce Investment Area

The Local Workforce Investment Area provides individualized services to assist

people in obtaining and maintaining satisfactory employment. Local Workforce Investment Area placement services are provided at no cost to eligible individuals

                                                                                                                                                                               

                        

10 Regions broken down to 23 LWIA which are based on colors (Image)

Low Income 637 24 20Receiving TANF 27 1 1

8 0 00 0 0

Receiving SSI 26 0 0137 0 5

Foster Child 45 0 0Homeless 9 0 0

60 1 11 0 0

Runaway Youth 0 0 0390 8 723 1 1

Offender 114 3 3342 2 2265 3 3232 2 1350 2 2

Single Parent 142 13 12Institutionalized 65 2 2Limited English 26 1 1

2 0 0

ExitersEntered EmploymentTotal WIA Participants Total Exiters

Public Assistance Recipient (TANF, GA, RCA, SSI)

Long Term Welfare Dependency

Basic Skills Deficient

Pregnant or Parenting Youth

Receiving General Assistance

Receiving Refugee Assistance

Receiving Food Stamps

Youth Who Needs Additional Assistance

Behind Grade Level

Individual with a Disability

Serious Barrier to Employment

Displaced Homemaker

Total 1,067 62 58Male 576 36 36Female 491 26 2214 - 15 205 1 016 - 18 131 1 119 - 21 50 2 222 - 29 110 11 1030 - 44 325 27 2745 - 54 187 14 1355 and over 58 6 5

Student 300 2 1School Dropout 142 6 6

358 31 29Equivalency/GED 80 10 9

187 13 13

White 771 57 53Black or African American 271 5 5Asian 9 0 0American Indian or Alaskan Native 2 0 0Hawaiian Native or Other Pacific Islander 0 0 0

Hispanic or Latino 67 3 3

Post High School Attendee

ExitersEntered EmploymentTotal WIA Participants Total Exiters

High School Graduate (No Post HS)

Pennsylvania Career Link office or participating

agency

Our Vision:Pennsylvania CareerLink is a cooperative effort to

provide one-stop delivery of career services to job seekers, employers and other Interesed Individuals. These services are also available in your local Pennsylvania CareerLink office or participating agency.

Our Mission:To function as a self-directed Job Search System

providing quality customer service to the people of Pennsylvania enabling all customers to make informed choices.

Our Goal:To provide a self service system in which interested

individuals have access to employment, education and training resources.

C

Employed 2Unemployed

Yes NoAmer/Al Native Asian

Black/ Af/

AmerHaw/Pac Island White

1 788 1607 639 17 2378 13 6 40 0 21432 82 158 74 2 238 5 0 2 0 2283 0 0 0 0 0 0 0 0 0 04 0 0 0 0 0 0 0 0 0 05 478 953 426 8 1423 8 4 25 0 13106 310 654 213 9 955 5 2 15 0 8337 19 75 0 2 92 0 0 2 0 938 769 1532 639 15 2286 13 6 38 0 20509 550 1049 367 13 1586 9 4 31 0 1428

10 161 348 186 2 507 4 1 6 0 45711 58 135 86 0 193 0 1 1 0 16512 728 1514 608 15 2227 12 6 35 0 200013 12 46 22 1 57 1 0 0 0 5514 83 297 70 1 379 2 0 9 0 35715 473 967 302 10 1430 5 2 22 0 134216 5 15 14 0 20 0 0 0 0 1717 3 17 4 0 20 1 0 0 0 17

1932241

58380

9423011599509

Referred to Support Services

14402020

Career Guidance

Job Search Activities

Referred to Employment

Referred to WIA Services

19 - 44

45 - 54

55 and over

Received Staff-Assisted Services

Employment Status at registration

Elegible Claimant

DHispanic or

LatinoTotal Job

Seekers

A

2395240

00

1431

Total Active Job Seekers

Youth

Adult (19 and over)

State: Pennsylvania

Expires: 04/30/05Breakout: _____

B

Cumulative for Four Quarters Ending 03/31/2004

Report Due: 05/15/04 OMB No. 1205-0240

E

Race

U.S. Department of Labor

Labor Exchange Programs

male

Female 964

ETA 9002 Quarterly Report

Services to Job Seekers

Veterans and Elegible Persons

MSFW

Interstate

G H I

In SchoolNot HS Grad

HS Grad or GED

Post-Sec or Cert

Total Total Total

1 602 73 849 663 25 0 6932 62 1 103 72 22 0 1013 0 0 0 0 0 0 04 0 0 0 0 0 0 05 366 35 515 388 25 0 4526 236 38 334 275 0 0 2417 48 6 33 3 0 0 08 554 67 816 660 25 0 6939 400 58 582 457 14 0 399

10 116 6 183 151 9 0 19411 38 3 51 52 2 0 10012 559 68 791 621 21 0 66113 14 3 24 15 0 0 3014 94 27 160 88 8 0 7915 356 44 562 438 16 0 30916 6 0 11 2 0 0 1417 6 0 11 5 0 0 4

OMB No. 1205-0240 Expires: 04/30/05

ETA 9002A Quarterly Report U.S. Department of LaborServices to Job Seekers Labor Exchange Programs

Persons w/disab. MSFW

Dislocated Workers

Cumulative for Four Quarters Ending 03/31/2004

Education

F

State: Pennsylvania Breakout: ____

Report Due: 05/15/2004

Total Active Job Seekers

Veterans and Eligible Persons

MSFW

Interstate

Male

Female

Youth

Adult (19 and over)

19-44

45-54

55 and over

Received Staff-Assisted Services

Career Guidance

Job Search Activities

Referred to Employment

Referred to WIA Services

Referred to Support Services

Clinton

Armstrong

Indiana

Fayette

Westmoreland

Washington

Greene

Allegheny

Beaver

Mercer

Lawrence

Butler

Venango

Erie

Crawford

BedfordSomerset

Fulton

Cambria

HuntingdonBlair

Forest

Clarion

Warren

Jefferson

Clearfield

Centre

McKean

Elk Cameron

Potter

Franklin

Lebanon

Cumberland

YorkAdams

Lancaster

Perry

Juniata

Mifflin

Dauphin

Montgomery

ChesterDelaware

Philadelphia

Bucks

Northampton

Berks

Lehigh

Schuylkill

ColumbiaMontour

Snyder

Union

Northumberland

Lycoming

Tioga

Sullivan

Bradford

Pike

Carbon

Luzerne

Monroe

Susquehanna

Wyoming

Lackawanna

Wayne

Pennsylvania UC Service Centers

Altoona UC Service Center, 17 April 2000

Duquesne UC Service Center, 29 October 2001

Scranton UC Service Center, 30 October 2000

Allentown UC Service Center, 17 November 1999

Philadelphia UC Service Center, 2 October 2000

Erie UC Service Center, 6 March 2000

Indiana UC Service Center, 1 October 2001 Lancaster UC Service Center, 11 December 2000

An Unemployment Compensation Service Center provides all unemployment

compensation services to our customers through direct telephone interaction between the customer and a UC representative using modern

telecommunications technology.

What is a UC Service Center?

Information to Collect

• Race

• Ethnicity

• Age

• Sex

• Disability status

White Black Hisp. Indian Asian INA Male Female INA 14-21 22-29 30-54 55+Initial Claims* 169,321 23,940 1,168 405 876 3,316 124,455 74,571 0 8,775 29,656 132,732 27,863New Claims 105,782 17,328 841 263 646 2,307 74,614 52,553 0 6,554 20,482 82,354 17,777Additional Claims 63,539 6,612 327 142 230 1,009 49,841 22,018 0 2,221 9,174 50,378 10,086

Monetary Determinations 240,163 42,770 1,900 588 1,330 5,360 172,024 120,087 0 13,289 45,181 189,954 43,687 Ineligible 11,342 2,749 133 46 72 351 8,928 5,765 0 1,440 3,003 8,843 1,407

Nonmonetary Determination 75,875 19,779 797 207 494 2,186 52,625 46,713 0 5,542 17,835 59,808 16,153 Invalid 27,470 7,872 304 78 197 846 19,747 17,020 0 2,214 6,947 23,236 4,370

Voluntary Q uit 9,388 2,290 122 31 49 276 5,538 6,618 0 838 2,516 7,592 1,210 Invalid 6,331 1,588 88 24 36 186 3,864 4,389 0 665 1,881 4,979 728

Misconduct 13,634 4,158 169 41 54 439 9,574 8,921 0 1,411 4,156 11,535 1,393 Invalid 4,468 1,825 52 14 19 171 3,568 2,981 0 616 1,537 4,038 358

Separation O ther 1,317 82 11 1 20 24 863 592 0 14 91 1,088 262 Invalid 338 26 7 0 8 8 248 139 0 3 21 309 54

Able & Available 1,328 269 4 3 6 32 943 699 0 134 382 947 179 Invalid 616 180 2 2 5 21 370 456 0 58 134 512 122

Disqual/Deductible 8,707 1,425 50 19 50 151 5,820 4,582 0 90 641 3,472 6,199 Invalid 2,291 681 18 4 16 59 1,861 1,208 0 143 376 1,913 727

Refusal of Work 385 99 6 0 2 12 245 259 0 30 88 275 111 Invalid 69 19 3 0 1 4 52 44 0 9 21 54 12

Report Requirement 6,938 1,507 38 12 68 208 5,590 3,181 0 476 1,565 5,775 955 Invalid 3,463 753 19 6 34 104 2,791 1,588 0 237 782 2,883 477

Nonsep. O ther - Valid 20,134 5,649 230 56 161 599 14,141 12,688 0 1,154 4,447 17,373 3,855 Invalid 9,894 2,800 115 28 78 293 6,993 6,215 0 573 2,195 8,548 1,892

* Excluding Transitional Claims

BREAKDOWN OF SUMMARY TOTALS

RACE SEX AGE

Service Center: 0998 From: 04/01/2003 To: 03/31/2004

TOTALS

Initial Claims* 199,026New Claims 127,167Additional Claims 71,859

Monetary Determinations 292,111 Ineligible 14,693

Nonmonetary Determination 99,338 Invalid 36,767

Voluntary Quit 20,409 Invalid 8,253

Misconduct 25,044 Invalid 6,549

Separation Other 1,842 Invalid 387

Able & Available 2,468 Invalid 826

Disqual/Deductible 13,471 Invalid 3,069

Refusal of Work 504 Invalid 96

Report Requirement 8,771 Invalid 4,379

Nonsep. Other - Valid 26,829 Invalid 13,208

* Excluding Transitional Claims

SUMMARY OF CLAIMS AND NONMONETARY DETERMINATIONS

PA Separation of Issue Chart

PA Separation of Issue Chart/ Race Ethnic

PA Separation of Issue Chart/ Gender

PA Separation of Issue Chart/ Age

Training:A

Key to Compliance/Monitoring

• The Office of Equal Opportunity believes that training all employees is an important key to compliance for (monitoring/data collection) all recipients of federal funds. Equal Opportunity training is mandatory for:

• State Employees• LocalWorkforce Investment Areas and Executive

Staff• CareerLinks-One Stops and Partners

Training (cont.)

• UC Service Centers

• OVR

• Training Providers

• Other Department of Labor & Industry Employees covered under WIA

Training conducted to date

• Methods of Administration

• Sexual Harassment

• Equal Opportunity Overview

• ADA/Section 504, Rehabilitation Act of 1973 as amended

• Limited English Proficiency

• Interviewing and Selection

Why use data as part of your review

• Two major reasons:

• Analyze data from output reports to identify significant differences, and;

• Identify all equal opportunity commitments made by the recipient.

Equal Opportunity Data Collection

• The purpose of equal opportunity data collection is to provide information from which valid judgments as to whether there are any indicators of discrimination in how a program or activity is being operated.

• Sufficient information must be collected to allow the EO Officer or monitoring staff to make comparisons.

• That all needed information is being put into the system.

• That all needed information can be extracted from the system, often through summary output reports.

• That he/she understands and can properly interpret an output report.

• And that appropriate analytical techniques are applied to the output reports.

What is Adverse Impact

• A selection rate for any race, sex, or ethnic group which is less than four-fifths (4/5) or eighty percent of the rate for the group with the highest rate will generally be regarded by Federal enforcement agencies as evidence of adverse impact.

Advantages and Disadvantages of the 80% Rule

• The 80% Rule has one great advantage over tests of statistical significance such as standard deviation- it is much simpler. Unlike tests of statistical significance, there is only one formula and it is always used the same way.

• There are some disadvantages.

• First it is imprecise. The 80% Rule always allows for a 20% variance between the most favored rate and the rate of others to which this rate is compared, regardless of the number of individuals in the total pool.

• In other words, the 80% Rule is insensitive to numbers. When there are few individuals in the total pool, a difference of 20% between groups may not be statistically significant.

• On the other hand, when there are many individuals in the total pool, a difference in rates of much less than 80% can be statistically significant.

• By using the 80% Rule, you can run the risk of identifying problems that really are not problems on the one hand, and failing to identify problems that do exist on the other.

• Second, the 80% Rule cannot measure certain kinds of differences. For example, the 80% Rule cannot be used to compare differences in the rates of pay among race/ethnic groups.

• Third, it is not the method used by CRC. CRC uses test of statistical significance, most often, the standard deviation.

Impact Ratio Analysis Question

• Terminations• 26 females are terminated out of 231 females employes

• 22 males are terminated out of 349 male employes

• Which is the least favored group?

• Why are they considered the least favored group?

• Does adverse impact exist?

• What is the IRA rate?

• Hires v. Applicants• There are 53 non-minority applicants, of which 25 are

hired.

• There are 86 minority applicants, of which 62 are hired.

• Which is the least favored group, and why?

• Does adverse impact exist, and why?

• At what point can you stop your calculations?

• For additional information please contact the Federal Unit:

• Ms. Crystal Adams: Chief of Federal Programs (717) 772-9195

• Ms. Ina Strain: EO Specialist Federal Programs (717) 772-9196