Upon receipt of the monitoring report, the LWIA Director will respond to the corrective action identified as to how the LWIA is going to implement the corrective activities described in the monitoring review. This written response is sent to the State WIOA EO Officer for review and approval. If on-site follow-up monitoring determines the causes for the initial finding have not been appropriately corrected, technical assistance is offered and further corrective actions are mandated. In the event follow-up activities are necessary, DCEO EO Compliance Monitors will schedule follow-up visits to ensure that corrective actions have been implemented.

IDES has also complied consistently with its obligations to monitor recipients for compliance seen under 29 CFR 38.51 through 38.53. A wide variety of data is collected and used to monitor local IDES offices with respect to both Unemployment Insurance and Employment Service programs. EO Monitors are responsible for evaluating both programmatic and physical accessibility compliance at each local office. Compliance reviews are conducted according to a fixed schedule and apply to both UI and ES programs. Section 1204 of the agency’s Policies and Procedures Manual describes procedures for monitoring of UI/ES programs in all local offices. (See EO Policies and Procedures 1200 through 1207 in the Rerences tab). There are various supporting documents which support this assertion and illustrate IDES’ programmatic and physical monitoring of its local offices.

1. Employment Service Monitoring
   
   Compliance reviews include on-site visits by EO Monitors and the examination of data related to the following services/activities: (1) registration taking; (2) job orders; (3) job referrals; and (4) job placements. Data is also analyzed with respect to UI benefits being granted across all protected EO categories to ensure there is no discriminatory impact on any protected group. Recommendations are made in any case where data indicates there may be a disparity. The data is analyzed as it applies to specific applicant groups according to race/ethnicity, sex, age, disability status, and LEP status. (IDES Local Office Monitor Reports)

   1.  Illinois JobLink (IJL)

      1. An attempt to identify significant statistical variations in the level of Employment Security (ES) service provided to the agency’s customers within the groups referenced above, both the “four-fifth” rule and provisions of the Equal Opportunity Data Requirements for Employment Service are used. To this end, the department has developed Illinois JobLink.

      2. The program uses the Employment and Training Administration 9173 statistical tables which are used to identify potential disparities among applicant groups. The tables provide data on the number of registrants, referrals, placements, wage patterns and other applicant services for each local office. The ETA tables evaluate services that different applicant groups receive and how these services affect their employability. The ETA data provides information on race/ethnicity, sex, age, disability status, migrant seasonal farm workers, and veteran applicant groups. ETA also provides a list of specific applicant services and job order information. As stated earlier, both the “four-fifths” rule and standard deviation are used to measure levels of service to applicants. Referrals, placement and wage information are broken down by occupational categories. ETA reports are generated on a regular basis. Additional reports are compiled upon request from the Civil Rights Center.

      3. Access to registrations and job orders is also available through Illinois JobLink. Samples of registrations and job orders are reviewed as part of local office monitoring process. The EO Auditing link available in IJL assists EO Monitors to review job orders job descriptions as well as referral and placement activities within the job orders. Applicant referral characteristics are provided within IJL EO Audit features. Additional EO employment service reports are available through the Data Analysis Reporting Tool (DART) as well as Federal reports to Employment and Training.

2. Unemployment Insurance Monitoring

   1. Compliance reviews include on-site visits by EO Monitors and the examination of data related to claims taking and adjudication. The data is analyzed as it applies to specific applicant groups according to race/ethnicity, sex, age, and disability status. (IDES Local Office Monitor Reports)

   2. As cited in the data and information collection section, data that includes applicant characteristics is collected through the Illinois Benefit Information System (IBIS). Statistical tables on monetary and non-monetary determinations are reviewed, as well as the number of claims processed, separation and non-separation determinations and appeals. All such reviews are conducted for each local office. The IDES Information Systems Bureau provides access to UI data and assists in generating a list of adjudicated cases by applicant groups and specific issues. From the list a sample of cases are selected for analysis. (IDES Local Office Monitor Reports)

3. Unemployment Insurance Appeals Monitoring
   The same general process for monitoring and evaluating UI and ES programs is followed with regard to the Appeals divisions on a quarterly basis. Both lower and higher authority decisions are examined to assess if one or more groups have a disproportionate lower number of favorable outcomes. Recommendations to address any issues are made when applicable.

4. Equal Opportunity Monitors (EO)

   1. The EO Monitors are under the direction of the EO Officer. The EO Monitors assist in planning and coordinating the monitoring of local office activities to ensure compliance with federal mandates. Principal duties include:  performance of statewide on-site visits, development of statistical computer-based reports involving the applications of complex mathematical and statistical methodologies. In addition, EO Monitors utilize mainframe systems and computer software programming language application, data collection, analysis, and report writing. The EO Monitors assist in the implementation, maintenance, evaluation and monitoring of procedures to ensure local offices are in full compliance with federal nondiscrimination requirements found in 29 CFR Part 38. Additional duties include the following:

      1. Prepares analysis of findings, using narrative, charts, tables and graphs; presents pertinent information to management through chain of command.

      2. Consults with other divisions and the Information Systems Bureau (ISB) to resolve technical problems, especially with regard to integrating the mainframe and PC systems.

      3. Makes recommendations to the Local Office staff on how to correct any issues identified in its monitoring of the Local Office.

      4. Follows up with the Local Office to ensure that all recommendations are followed and when necessary implemented.

      5. Assists in any additional training of Local Office staff when necessary.

   2. Section 1204 of the agency’s Policies and Procedures Manual provides a detailed description of the system for monitoring UI/ES offices. Since 1996 on-site reviews have been conducted on a monthly or quarterly basis. The EO office has developed a local on-site review guide which details activities of the EO Monitor when preparing for and conducting the on-site review. (See EO Policies and Procedures 1200 through 1207 in the Rerences tab).

   3. The responsibilities of an EO Monitor, when conducting on-site reviews, include the observing intake and referral processes, interviewing local office staff, determining the office's compliance with equal employment opportunity directives such as the posting of required notices and conducting any necessary training regarding Nondiscrimination regulations. On-site visits are also conducted to comply with requests from the Civil Rights Center for specific data on designated offices. The following sequence illustrates the preparatory stages of these reviews as well as activities undertaken while at the local office, and includes all actions through the final report writing:

      1. Notification of Local Office On-Site Review
         The EO Monitor notifies the local office manager of scheduled site visit and then follows up with a phone call to ensure local office management will be available for the review.

      2. Data Collection

         1. The EO Monitor collects and reviews census data on local population, civilian labor force and civilian unemployment labor statistics. Data is provided through the Economic Information and Analysis Bureau (EI&A) and is accessible through the IDES web page.

         2. The EO Monitor collects and reviews employment service data. Also, reviews data from federal report (ETA 9002). Runs summary tables from IJL program. Reviews data for statistical disparities in referrals, placements and service. The EO Monitor runs detailed reports pertaining to job orders and applicants using the IJL program and requests Ad Hoc reports from IJL for additional detailed data.

         3. The EO Monitor collects unemployment data from the Illinois Benefit Information System (IBIS). The EO Monitor requests five summary tables:  claims, monetary determinations, non-monetary determinations, separation determinations and non-separation determinations. The EO Monitor creates statistical tables on “allow” rates and “denial” rates.

         4. The EO Monitor collects employee staff characteristics of the local office and identifies the number of available employees providing interpretive services.

         5. The EO Monitor obtains telephone report from Propio Language Services regarding local office usage of interpretive telephone language services and performs an analysis to determine if our LEP requirements are being sufficiently addressed.  (IDES Local Office Monitor Reports)

      3. On-Site Review

         1. Entrance interview with local office manager/supervisor

            1. Review employment service data and statistical disparities.

            2. Review unemployment insurance data and statistical disparities.

            3. Review availability of assistive devices and software for individuals with disabilities.

         2. Desk reviews

            1. Request from local office UI manager/supervisor one or two days of applications taken during the last ten (10) days. Select an appropriate number of applications for review.

            2. Check UI applications for EO documentation.

            3. Check accurate collection of EO data (race/ethnicity, sex, age, and disability status).

            4. Request a sample of adjudication cases by applicant characteristics and request Benefit Total Quality (BTQ) reviews for the previous two or three months.

               1. Review separation determinations.

               2. Review non-separation determinations.

               3. Review BTQ cases.

            5. Review a random sampling of registrations from the applicant groups and select those that have been identified as having received a disproportionately low number of referrals, placements or services.

               1. Review number of skills listed.

               2. Review skill experience of applicants.

               3. Review services provided to the applicant.

            6. Review local office complaint log for past three years.

            7. Review facility for accessibility using the following ADA checklist and guidelines.

               1. Public Parking; check for adequate parking spaces for the disabled and appropriate signage.

               2. Office Entrance; check entrance for accessibility.

               3. Universal Signage; identify accessibility and room identification as well as assistance signs.

               4. Restrooms: check restrooms for ADA compliance.

               5. Public Service Areas; check accessibility to resource rooms, training rooms and other public service areas. Is reception area clearly defined for applicants?

               6. Public Telephone; accessibility.

               7. Water Fountain; accessibility.

         3. Inspection of EO posters, EO pamphlet/notices and ADA poster

            1. Are EO Notices (poster) posted in a prominent location?

            2. Is EO Notice posted in a language other than English, where appropriate?

            3. Are EO Notices (8 ½” X 11” handouts) provided to applicants/the EO Monitor claimants?

            4. Is EO Notice available in languages other than English?

            5. Is the American with Disabilities Act poster displayed conspicuously?

         4. Observation of Staff Interaction with Clients

            1. Observe if Benefit Rights are provided to claimants.

            2. Observe coaching of applicants registering for employment service Illinois JobLink (IJL).

            3. Observe adjudication interviews.

            4. Observe language assistance.

         5. Local office interviews with selected staff

            1. Determine which staff should be interviewed based on local office manager/supervisor description of staff assignments.

            2. Selected staff should include employees conducting activities in employment service, veteran’s assistance, unemployment insurance and reception.

            3. When possible, selected staff should include females, minorities and persons with disabilities.

         6. Exit conference

            1. Verbally review local office findings and tentative recommendations with manager/supervisor. Official recommendations from the EO Officer are presented with the final written report.  (IDES Local Office Monitor Reports)

      4. Draft Final Report with Findings and Recommendations (Report and Corrective Action Plan)
         After completion of an on-site review, the EO Monitor prepares a written summary of his/her conclusions and recommendations. A draft report is submitted to the EO Compliance Supervisor and EO Officer for review and approval. The report is then forwarded to the appropriate manager and Operations Deputy Director for response and development of any needed corrective action plan. The corrective action plan, including specific steps to be taken, due dates and identification of each responsible person, is then included in the Final Report. The Final Report is approved by the EO Officer and submitted to the Director. Operations management is responsible for taking appropriate steps to ensure compliance with any related corrective action plan, and the EO Office is responsible for conducting any necessary follow-up. The Final Report includes the following items:

         1. On-site review findings and recommendations

            1. ADA facility requirements

            2. EO posters, EO pamphlets/notices and ADA poster

            3. Staff interviews

            4. Language assistance

         2. Employment Service findings and recommendations

            1. Referrals and Placements

            2. Wage patterns

            3. Non-Service

            4. Registrations

            5. Job orders

         3. Unemployment Insurance findings and recommendations

            1. Allow/Denial rates

            2. Adjudication reviews

            3. EO documentation

            4. EO data collection

      5. Conducting Follow-Up

         1. Operations Bureau formally responds in writing to the recommendations.
            A copy of Operation’s response is included in the final report and the report is sent to the EO Officer for review and approval. The Director of the Bureau receives the final report in its entirety.

         2. Follow up with local office occurs within scheduled monitoring timetable or as directed by the EO Officer. (IDES Local Office Monitor Reports)