PWS_Attachment_19-YCP-Template_Report_of_Inspection_Package.pdf

ChalleNGe Operational and Resource Effectiveness

(INSPECTION TEAM)

Program

Report of Inspection

XX State YC Program ChalleNGe Academy

__ 2016

____, 2016

Chief, Office of Athletic and Youth Development 111 South George Mason Drive, AH2, Arlington, VA 22204-1373

During the period ___ 2016, XX State YC Program ChalleNGe Academy received a full-scope ChalleNGe Operational and Resource Effectiveness (INSPECTION TEAM) Inspection.

The enclosed Joint Lessons Learned Program (JLLP) formatted document provides a detailed explanation of the areas of noncompliance and shortcomings in performance. In response to this inspection you will develop and submit a Corrective Action Plan (CAP) that addresses each of the Resource Management and Operational Compliance and Unsatisfactory Performance findings contained in the Report of Inspection (ROI).

If you have any additional questions or concerns please contact me at______

XXXXX

Contract Company

_______, 2016

Chief, Office of Athletic and Youth Development 111 South George Mason Drive, AH2, Arlington, VA 22204-1373

During the period ____ ___ 2016, XX State YC Program ChalleNGe Academy received an Operational compliance inspection. The Program received an “Excellent” rating with a 91.88% level of compliance with the legal, regulatory, and doctrinal operational requirements of the Youth ChalleNGe Program.

The Program is at Training Level T-4 as defined by the Cooperative Agreement. Due to an absence of low-density NGB-required function-specific (Counselor, Recruiter, Educator, Post-Residential, and Supervisory) and refresher training courses, XXXX has been unable to provide the required professional development training for staff members. The ongoing training committee initiative at the national level is developing the needed training courses. As stated in the email from Mr. Jeffrey White dated May 11, 2016 with the subject line Final Youth ChalleNGe Training Policy Letter [Effective 15 May 2016], “For all federal training programs that we release in the coming months (i.e.

functional courses) programs will have 3 months from release before being held accountable for policy timelines for inspection purposes.” The Basic Course and Cadre Course were both included in the calculation of the Compliance Component scoring and rating. Although the remaining low-density NGB-required function-specific staff training courses were inspected, the results were not calculated in the final rating. Additional areas of noncompliance include the Program accepting applicants who do not meet all eligibility requirements to attend the program, the inability to meet Graduation Target for the last four classes due to an insufficient Acclimation period pool of candidates and/or high attrition rate, lack of submission of required Serious Incident Reports (SIR) for alleged Hands-Off Leadership Policy violations, and deficiencies with the Post- Residential requirements. Professional development training and Post-Residential standards are systemic areas of noncompliance Program-wide.

If you have any additional questions or concerns, please contact me at ___________

XXXXXXXXXXX

Contractor

XX State YC Program Operations _______

2016 Report of Inspection

1. a. FINDING: (Systemic) XX State YC Program ChalleNGe Academy accepts participants into the Program who do not meet all of the eligibility requirements. (Participants, Item #’s 1a and 1d)

b. DISCUSSION: Department of Defense Instruction (DoDI) 1025.8, paragraph

4.10.1 states, “Selection of participants for the programs established under this Instruction shall be from applicants who meet the following eligibility standards: 16-18 years of age at time of entry into the program.” National Guard Youth ChalleNGe Program Cooperative Agreement (NGYCP-CA), Section 201, paragraph e(3)(a) states, “The Grantee agrees to select participants from applications who meet the following eligibility standards: 16-18 years of age at the time of entry into the Program.

Participants will not exceed 18 years of age on the 1st day of the Residential Phase.”

ChalleNGe Publication 3-1, (CP 3-1) Chapter II, paragraph 6A states, “Applicants will meet the following minimum eligibility standards: A citizen or legal resident of the United States and resident of the state in which the program is operated or with whom the program has a memorandum of agreement.”

During the inspection, the Deputy Director provided that two participants had been accepted into the Program who had not reached their 16th birthday on Day 1 of the Acclimation Period. He stated that both participants turned 16 years of age on Day 3 of the Acclimation Period. This is a systemic area of noncompliance as this same issue was found during the August 2014 INSPECTION TEAM inspection. In the Corrective Action Plan (CAP) dated 31 October 2014, the Program Director stated, “The XX Director has ceased allowing youth to register on R-Day who are within nine days of their 16th birthday. This “Age Waiver” change was implemented on Tuesday, 16 September 2014. All future XX registrants will be IAW established eligibility requirements per DODI 1025.8.” Although this corrective action had been implemented, a decision was made to again accept participants who were not the correct age at the start of the Acclimation Period, resulting in XX being out of compliance.

In addition to accepting participants who are not the correct age, XX is also accepting participants who are not residents of the state of XX State YC Program. This was a finding during the August 2014 inspection, making this a systemic area of noncompliance. In the CAP dated 31 October 2014, the Program Director stated, “XX accepts non-resident applicants from neighboring or nearby states who do not operate a NGYCP or who were referred to XX State YC Program from another state’s NGYCP because they could not accept the youth. XX does not recruit in these states but also does not turn-away interested youth/families who contact XX from these states. Once XX routinely reaches maximum per class capacity of registered residents it will no longer accept non-resident applicants. The XX State YC Program Military Department has decided it will not pursue a Memorandum of Agreement (MOA) or

Understanding (MOU) between itself and the military departments of neighboring or nearby states from which the program accepts non-resident youth. Because the MD does not have any expectation of monetary reimbursement from these states an MOA or MOU is not needed. XX will continue accepting XX State YC Program non-residents for the foreseeable future.” For Classes 29 and 30, 15 of the 43 and 13 of the 41 participants respectively were from outside the state of XX State YC Program. Some of the states where the participants were from include ___________. The first three states (_______) all have Programs of their own. It is clear from the response provided in the October 2014 CAP that XX will continue to accept out of state participants and will accept the finding of noncompliance in this area.

c. RECOMMENDATION: XX’s Admissions, Placement, and Mentoring

(APM) Department must reject any application from a participant who has not reached his/her 16th birthday by Day 1 of the Acclimation Period. If a participant is otherwise fully eligible, he/she should be waitlisted for a future class. To counter the risk of the participant losing interest, the APM Department should maintain a constant line of communication with the applicant until the class start date. If XX will continue to accept participants from outside the state of XX State YC Program in violation of the DoDI and NGYCP-CA, the Director should report those numbers to NG-J1-AY at the start of each class cycle.

d. IMPLICATION: When XX accepts an applicant who does not meet the minimum age eligibility requirement at the start of the Acclimation Period or accepts an out-of-state applicant without a valid MOA/MOU with the applicant’s state, the Program is in direct violation of NGYCP-CA, DoDI 1025.8, and CP 3-1. As stated in the INSPECTION Team’s Report of Assessment from the August 2014 on-site, “accepting applicants who do not meet the age eligibility requirement this could become a liability issue. Because the Acclimation Period is conducted in a quasi-military environment and can be demanding and often times physically challenging, should a candidate be injured during the course of training a subsequent investigation would most likely look at the candidate’s eligibility to be enrolled in the Program. The fact that the candidate would be found to be underage could result in the Program assuming all legal liabilities.”

Since participants from outside the State of XX State YC Program are being used to help achieve graduation target, XX could have its funding adjusted based on the actual number of XX State YC Program residents graduated. Although XX is unique in its four classes per year model with two of those classes being funded with 100% state monies, it is still imperative that performance metrics be achieved. In an agreement with NG-J1- AY, XX’s graduation target has been adjusted to 30 cadets per class or 120 per year.

NGYCP-CA Section 1-9 paragraph b. clearly states, “NGB may terminate a Program if performance metrics remain below the minimum standards. Programs producing below 75 graduates per class, or 150 graduates per year, are not cost effective.”

2. a. FINDING: (Systemic) XX State YC Program ChalleNGe Academy staff does not meet the in-house training standards. (Organization, Item #’s 23a and 23c)

b. DISCUSSION: ChalleNGe Publication 3-1 (CP 3-1) Chapter II paragraph 8.D states, “In-house staff training such as first aid, CPR, gang awareness, and conflict resolution are also imperative to staff readiness.”

During the August 2014 INSPECTION Team Evaluation, the Program was found to be out of compliance in the area of in-house training. This issue is systemic since several staff members were in need of in-house training during this inspection. The following strategies were included in XX’s Corrective Action Plan from the October 2014 INSPECTION Team Evaluation: “XX has modified its new-hire In-Processing Checklist procedures to ensure all employees complete CPR and First Aid training within two weeks of their date of hire (DOH) and NLT four weeks of DOH. The training date will be coordinated and planned by XX Admin, written on the new employee’s In- Processing Checklist, and executed as scheduled. XX has implemented the same new process and associated consequences listed above for CPR training to the scheduling and accomplishment of conflict resolution (i.e. CPI) training. This new procedure applies to both the academic and physical portions of CPI. This new procedure was put into effect on 19 Aug 14.” The acting Program Director provided that XX has implemented their corrective actions; however, full compliance has not been achieved. Out of 39 staff members, 5 staff members require CPR/First Aid training, and 4 staff members require conflict resolution training. The staff members that require the in-house training were recently hired within the last 6 months. The acting Program Director stated the five staff members who have not completed CPR/First Aid training was a result of lack of training material and that once the material is received they will complete the training. He also stated conflict resolution training will be completed by the end of August 2016.

c. RECOMMENDATION: XX must ensure all staff members complete the in-house training as required in the CP3-1. The Program leadership must ensure that all required in-house training is scheduled and conducted. XX should continue to include in-house training as part of the in-processing requirements of new hires.

Providing in-house training before the employee begins official duty will enable XX to meet all requirements and will address the instances when employees are on leave or sick during regularly scheduled cycle-break training. Upon completion of all in-house training, the Program Director must continue to ensure the data is updated in a data management system to reflect the Program’s accurate training level. Once the data is updated in a data management system, the Program’s training officer should continue to maintain detailed files such as sign-in rosters, certificates of completion, etc., to validate the completion of all required training.

d. IMPLICATION: NGYCP-CA, Section 1-9, paragraph g clearly states, “Leadership and Staff professional development is to equip leaders and Staff with the skills, knowledge, and networks necessary to intervene in and reclaim the lives of at-risk youth and to produce responsible and productive citizens.” Not providing the required training contradicts its design as stated in NGYCP-CA, “The training is designed to minimize the risk of serving youth in need.” The implication of having untrained staff working directly with minors and at-risk youth exposes XX to nearly limitless legal liability. Training deficiencies influence all phases of XX to include the achievement of the mission and the sustainability of the Program.

3. a. FINDING: XX State YC Program ChalleNGe Academy’s Corrective Action Plan (CAP) submitted on 30 October 2014 did not meet all requirements.

(Administrative Requirements, Item #’s 26c and 26d)

b. DISCUSSION: The National Guard Youth ChalleNGe Program Cooperative Agreement (NGYCP-CA), Section 1-2b(5) states, “Evaluation teams shall not only assess current operations and resource management activities, they shall also review findings from the previous year to determine whether corrective actions have been taken where warranted, and include these findings in each report.” In his cover Memorandum dated 14 August 2014 to the ChalleNGe Operational and Resource Effectiveness (INSPECTION TEAM) Report of Assessment (ROA), Mr. Chad Volgelsang, Chief, Office of Athletics and Youth Development, wrote, “In response to this assessment, you will develop and submit a detailed, written Corrective Action Plan (CAP) that addresses each of the Resource Management and Operational Compliance and Performance findings contained in the Report of Assessment. The CAP will include a cover memorandum addressed to this office that is signed by the Program Director.

The memorandum will summarize the CAP and provide sufficient enclosures to address each finding. It is imperative that the enclosures detail the systems and processes that you either develop, or refine, to correct the deficiencies. The CAP is due 60 days from receipt of this memorandum to Maj Karen Patrick (Karen.S.Patrick2.mil@mail.mil) and Mr. Chad Vogelsang.”

XXX submitted their CAP on 30 October 2014 for the INSPECTION TEAM Evaluation conducted 12-14 August 2014. A review of the CAP revealed that the Program Director addressed all areas of noncompliance from the Operations Compliance component, but failed to address areas from the Operational Performance component rated as “Unsatisfactory.”

Participant eligibility, in-house training, a sufficient Acclimation Period pool of prospective Cadets, and mentor requirement remain unresolved and are thus systemic areas of noncompliance.

For the issue of participants not being 16 years old on Day 1 of the Acclimation Period, the Program Director stated in his CAP dated 30 October 2014, “The XX Director has ceased allowing youth to register on R-Day who are within nine days of their 16th birthday. This “Age Waiver” change was implemented on Tuesday, 16 September 2014.

All future XX registrants will be IAW established eligibility requirements per DODI 1025.8.” For accepting out of state participants, the Director stated, “XX accepts non-resident applicants from neighboring or nearby states who do not operate a NGYCP or who were referred to XX State YC Program from another state’s NGYCP because they could not accept the youth. XX does not recruit in these states but also does not turn-away interested youth/families who contact XX from these states. Once XX routinely reaches maximum per class capacity of registered residents it will no longer accept non-resident applicants. The XX State YC Program Military Department (MD) has decided it will not pursue a Memorandum of Agreement (MOA) or Understanding (MOU) between itself and the military departments of neighboring or nearby states from which the program accepts non-resident youth. Because the MD does not have any expectation of monetary reimbursement from these states an MOA or MOU is not needed. XX will continue accepting XX State YC Program non-residents for the foreseeable future.” Compliance has not been achieved in these areas.

For not meeting in-house training requirements the Director stated in his CAP, “XX has modified its new-hire In-Processing Checklist procedures to ensure all employees complete CPR and First Aid training within two weeks of their date of hire (DOH) and NLT four weeks of DOH. The training date will be coordinated and planned by XX Admin, written on the new employee’s In-Processing Checklist, and executed as scheduled. XX has implemented the same new process and associated consequences listed above for CPR training to the scheduling and accomplishment of conflict resolution (i.e. CPI) training. This new procedure applies to both the academic and physical portions of CPI. This new procedure was put into effect on 19 Aug14.”

Compliance has not been achieved in this area.

Not meeting graduation target due to an insufficient Acclimation period pool of prospective cadets was also addressed in the CAP. The Director stated the following strategies, “1) Reduced size of Cadet Application; 2) Improved ease of understanding and readability of Cadet Application; 3) Increasing number of XX recruiters from three to five and will reduce the size of assigned regions; 4) Maintained or expanded current state-wide and regional advertising and marketing; 5) Contracted on-site staff training from NGYCP experts; 6) Sent two staff to ____ cadre training course; 7) Planning key staff visits to sister NGYCP to observe and learn other methods of operations; 8) Re-proposing legislation to acquire high school dropout lists from state-wide school districts; 9) Expanding XX visibility through 30-minute o PBS TV “Chronicles” episode; 10) Re-defined Recruit Team and created and implemented improved team processes to increase efficiency and effectiveness.” Compliance has not been achieved in this area.

The Program Director also addressed the noncompliance issues associated with the Post-Residential mentor requirements. For not having all Cadets matched with their mentors by the end of Week 13 the Director stated in his CAP, “XX has developed and implemented a formal “matching” event for cadets and mentors that began 25 Oct 14 (Class 23). Specifically, the “Mentor Match Ceremony” to be held the afternoon of scheduled Mentor Training days will include 1) an official certificate signed by the Director, Case Manager, Cadet and Mentor; 2) a certificate holder; 3) a photo of cadet and mentor holding the certificate; and 4) the photo will be posted on Facebook.” The strategies implemented to resolve the noncompliance issue associated with mentors not making their monthly contact requirements and placement verifications include the following, “1) overall increased emphasis from the Director (time and attention) to the staff, cadets, family members and mentors on the Post-Residential Phase; 2) updated the script for both the Awards Banquet and Graduation ceremonies to increase Post- Res Phase awareness; 3) instituted use of a dedicated phone bank located in the Computer Lab to minimize distractions, improve relationships, and to create predictability/stability for the cadet and mentor; and 4) adjusted internal procedures to better facilitate weekly Mentor Phone Calls starting Week 13 of the Residential Phase IOT improve rapport and trust between cadet and mentor and to open lines of communication. Case Managers have placed added emphasis on this item in the slides and in their verbal instructions on Mentor Training Day. When Case Managers speak to mentors via phone, email or Facebook they remind mentors of this requirement (as needed). Case managers will verify and obtain required documents for placement.”

The APM Coordinator provided that XX has implemented their corrective actions;

however, full compliance has not been achieved.

c. RECOMMENDATION: A CAP response is required for all NO GOs from the Operations Compliance checklist and all ratings of “Unsatisfactory” from the Operations Performance checklist. The Program Director must ensure all areas of noncompliance and unsatisfactory performance are addressed in detail in the CAP with the systems and processes that will be developed or refined to correct the deficiencies. Then, XX staff must constantly monitor the status of the corrective action strategies to determine whether the desired results are being achieved. If they are not, the Program Director must determine whether any unexpected obstacles or any other issues are preventing the Program from reaching compliance. Once a thorough review has been conducted, the staff should amend the strategies in an effort to bring all issues into compliance.

d. IMPLICATION: The CAP must be a living document which the staff must constantly monitor to determine its effectiveness. Without a workable plan, compliance will not be achieved. A Program that accepts noncompliance issues as unsolvable just because they are systemic does nothing to move itself toward compliance. Failure to identify workable solutions to noncompliance issues in the CAP will cause the Program to stagnate and accept mediocrity. Programs which do not meet acceptable compliance levels or fail to achieve performance standards are in danger of losing funding or, in a worst case scenario, be terminated. Loss of the XX would take away the opportunity for struggling teens to turn their lives around and become productive citizens in their communities.

4. a. FINDING: XX State YC Program ChalleNGe Academy did not meet all requirements of the biennial Director’s Self-Assessment (DSA).

(Administrative Requirements, Item # 27d)

b. DISCUSSION: National Guard Youth ChalleNGe Program Cooperative

Agreement, Section 201, paragraph d(3) states, “The Grantee shall develop Standing Operating Procedures (SOPs) for all key areas of their Program. SOPs may take the form of handbooks, guides, manuals, etc. The SOPs will ensure they include the requirement for Program Directors to perform a bi-annual operational self-evaluation.”

In accordance with an email from Mr. Jeffery M. White, Chief, NG-J1-AY dated 25 March 2015, XX was required to complete the INSPECTION TEAM Director’s Self- Assessment and identify all areas of noncompliance. Mr. White stated in his email, “Please complete the attached Director's Self Evaluation template and return to me, Maj Patrick and the ___ team (___and ____) by 1 May 2015.” The purpose of this Self- Assessment is to provide the Program Office with the assurance that each program is operating in compliance with standards and to provide information for use in development of the Annual Report to Congress. The Director’s Self-Assessment is an integral part of the Program’s next onsite inspection. The INSPECTION TEAM will evaluate the content of the Director’s Self-Assessment to determine its validity and efficacy.

The DSA was submitted on 1 May 2015. The Director identified all areas of noncompliance in the Operations Compliance checklist and accurately assessed the standards in the Operations Performance checklist. The Program Director commented on the noncompliance issues associated with Cadet eligibility, in-house training, and Post-Residential requirements. Resolution of these areas has not yet been achieved. Post-Residential requirements have been identified as systemic areas of non-compliance Program-wide.

c. RECOMMENDATION: The INSPECTION team takes a critical look at the last DSA submitted to NG-J1-AY during onsite Program inspections. Specifically, inspectors determine if the DSA was submitted within the required timeframe, whether or not all areas of non-compliance were identified, and, after the completion of the on-site inspection, whether all identified areas of non-compliance were resolved. When completing and submitting the DSA to NG-J1-AY, the Program Director must thoroughly review each requirement. It is recommended that if a Program Director is unsure whether particular items are in compliance or not, seek further guidance from the Program Office. An honest, unbiased look at the standards is necessary to make any needed changes to ensure the Program is moving toward 100% compliance and satisfactory or better performance.

d. IMPLICATION: Failure to identify noncompliance issues in the DSA gives the Program Office (NG-J1-AY) an inaccurate picture of the Program’s status. Without a comprehensive, accurate DSA, the Program Office cannot address systemic areas of noncompliance such as professional development training and Post-Residential standards. An accurate assessment of the Program also assists NG-J1-AY in determining where to provide needed resources.

5. a. FINDING: XX State YC Program ChalleNGe Academy staff does not adhere to all requirements of the Hands-Off Leadership Guidance.

(Administrative Requirements, Item #’s 37a, 38b, 38d, and 39a-39c)

b. DISCUSSION: The ChalleNGe Program “Hands-Off Leadership” Policy from Chief, NG-J1-AY dated 8 May 2015 states, “ChalleNGe staff will be trained on the

"Hands-Off Leadership" policy prior to supervising Cadets. Once training is complete, programs are required to update a Data Management System (DMS) and retain documentation for future audits and inspections. Staff training will require any staff member, observing or witnessing any violation of this directive, to be responsible for immediately reporting it to their superior or the next member in the chain of command, and to fail to do so is, in itself, a violation of the policy. Likewise, any employee who violates this directive is required to document their actions and report it to their superior immediately.” In addition, the Hands-Off Leadership Policy states, “All reports of an alleged violation of Hands-Off Leadership by a ChalleNGe staff member shall be impartially investigated and facts gathered under the direction of senior staff.

Appropriately document the investigation facts and forward to the Director for action.

NGB-J1-AY shall be notified via a Serious Incident Report anytime a Program Director conducts an investigation regarding an alleged inappropriate event.” NGYCP-CA Section 1-12 paragraph f states, “All reports of an alleged violation of Hands-Off Leadership by a Program Staff member shall be impartially investigated and facts gathered under the direction of senior Staff. This shall be appropriately documented and forwarded to the Program Director for action.”

During the Cadet interviews, a Cadet made an allegation that a Cadre Team Leader (CTL) touched and/or restricted the movement of a Cadet in violation of the Hands-Off Leadership policy. The alleged violation occurred during a community service project.

The Commandant was made aware of the alleged violation from the CTL’s supervisor.

The Commandant was told that the CTL’s supervisor spoke to the Cadre about her behavior; the Commandant determined there was no validity to the allegation and no internal investigation was conducted. The Commandant failed to inform his chain of command of the incident. Thus, the acting Program Director was not made aware of the incident and did not assign a staff member to conduct an impartial investigation, the facts of the allegation were not gathered under his supervision, and no results of even the informal investigation by the Commandant were forwarded for Program director’s action. A Serious Incident Report (SIR) of the alleged violation was never sent to NG- J1-AY. It must be noted that these requirements are found in the AY Hands-Off Leadership Policy from Chief, NG-J1-AY dated 8 May 2015. The acting Program Director did not have a copy of that policy so was unaware of the requirement to report an alleged violation to NG-J1-AY via an SIR, nor was the staff trained on the requirements of that policy.

c. RECOMMENDATION: The Program Director must review and follow the guidelines stated in the NGYCP-CA and in the AY Hands-Off Leadership Policy for any alleged violation of Hands-Off Leadership Guidance Policy by a Program Staff member. The Hands-Off policy must be a constant theme discussed during all staff training evolutions, to include the point that it only takes an allegation of a violation, not an actual witnessed violation, to trigger the investigative process. The senior staff, as required by the NGYCP-CA, must direct the investigation, and the Program Director must ensure that he receives the results of the investigation for his action.

In addition, the Program should review the Hands-Off Leadership SOP and training to ensure that it includes, at a minimum, how a complaint is reported, to whom it is reported, how it is investigated, and the courses of action to be taken if the allegation is confirmed.

160728 INSPECTION TEAM Ops

Compliance Checklist Effective 160101 Page 1 of 36

Establishing a clearly defined process will ensure future allegations of violations are handled in a consistent, appropriate, and timely manner.

d. IMPLICATION: Any violation of the Hands-Off Leadership Guidance Policy by a staff member to a Cadet is an extremely serious situation. For that reason, investigating all violations, both alleged and observed, is of utmost importance to ensure the safety of the Cadets remains the top priority of the Program. It may be difficult for a Program to overcome the reputation that it does not take allegations of Hands-Off Policy violations seriously, which may lead to an even smaller Acclimation Period pool of candidates as they may tend to look at other intervention alternatives. The implications of not having an effective Hands-Off Leadership Guidance policy in place include increasing the Program’s risk of physical and emotional harm to its Cadets, potential widespread public scrutiny, and significant legal liabilities. Failing to adequately investigate and respond to all violations of the Hands-Off Leadership Guidance policy eventually creates a culture where physical and mental abuse is the norm, placing the safety of Cadets in jeopardy.

ChalleNG e Operational and Resource Effectiveness Team

Program/State: ChalleNGe Academy, XX State YC Program

Date: XX- July 2016

Functional Area: Operations

Compliance Rate: 91.88%

Information: K a r e n S . P a t r i c k , 7 0 3 - 6 0 7 - 2 7 5 4 , K a r e n . S . P a t r i c k 2 . m i l @ m a i l . m i l

TASK: Maintain Operation Readiness

CONDITION: Given an assignment to the National Guard Youth Challenge Program and applicable references

STANDARD: Using guidance provided in DoDI 1025.8 (Mar02), ChalleNGe Publication 1 (Dec09), ChalleNGe Publication 3-1

(Sep10), National Guard Youth ChalleNGe Program Cooperative Agreement (NGYCP-CA) (Jan12), Recruiting, Placement and

Mentoring Operations Manual (26Mar14), NG-J1-AY ChalleNGe Program Hands-Off Leadership Policy dated (8May15), NGYCP-

CA, Section 201, paragraph d(3), INSPECTION TEAM Program Manager Email containing the Memo from Chief, NG-J1-AY and

Chief National Guard Bureau Instruction 9350.01 (Nov15)

Terminal Task Item Enabling Task Participants

NO GO

1. Do the participants of the Program meet the required eligibility standards?

Ref: DoDI 1025.8, paragraph 4.10.; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3); and, Recruiting, Placement and Mentoring Operations Manual.

Inspected Item: Questions 1a–1g below.

Reviewed 14 Cadet applications from Classes 29 and 30.

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1a. Are participants sixteen to eighteen years of age at time of entry into the Program?

Note: Applicants will not exceed 18 years of age on the 1st day of the Residential Phase.

Ref: DoDI 1025.8, paragraph 4.10.1; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(a); Recruiting, Placement and Mentoring Operations Manual, page 5.

Inspected Item: Copy of birth certificate in completed Cadet applications.

Systemic: Two Cadets were not sixteen years of age on the first day of the Residential Phase.

Age was verified using the birth certificate.

1b. Are participants high school dropouts (i.e., no longer attending school and not having been awarded a secondary school diploma or equivalent certificate)?

Ref: DoDI 1025.8, paragraph 4.10.1; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(b); Recruiting, Placement and Mentoring Operations Manual, page 5.

Inspected Item: School release form or signed statement certifying accuracy of information contained in the completed Cadet applications.

Dropout status is determined by from the Cadet application.

GO

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1c. Are participants citizens or legal residents of the United States?

Ref: DoDI 1025.8, paragraph 4.10.3; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(c); Recruiting, Placement and Mentoring Operations Manual, page 5.

Inspected Item: Copy of birth certificate in completed Cadet applications.

Citizenship was verified using the birth certificate.

1d. Are participants residents of the state in which the Program is operated or with whom the Program has a memorandum of agreement?

Ref: CP 3-1, Chapter II, paragraph 6A.

Inspected Item: Review home address in completed Cadet applications.

Systemic: On Day 1, 15 of the 43 Cadets in Class 29 and 13 of 41 in Class 30 were from states other than including: XX, and XX. Residential status was determined from the Cadet application.

1e. Are participants unemployed or underemployed?

Ref: DoDI 1025.8, paragraph 4.10.4; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(d); Recruiting, Placement and Mentoring Operations Manual, page 5.

Inspected Item: Review employment questions and signed statement certifying accuracy of information contained in the completed Cadet applications.

Cadet application was used to determine the participant's employment status.

1f. Are participants of the Program not currently on parole or probation for other than juvenile status offenses, not awaiting sentencing, not under indictment, charges, or convicted of a crime that is considered a felony if charged as an adult?

Ref: DoDI 1025.8, paragraph 4.10.5; and NGYCP-CA, Section 201, paragraph e(3)(e).

Inspected Item: Review criminal background questions and signed statement certifying accuracy of information contained in the completed Cadet applications and any other official criminal background checks.

Legal status of participants (i.e. parole, probation, felonies) was determined from the Cadet application.

1g. Are all participants of the Program free from use of illegal drugs or substances?

Ref: DoDI 1025.8, paragraph 4.10.6; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(f); Recruiting, Placement and Mentoring Operations Manual, page 5.

Inspected Item: Review illegal drugs or substance questions and signed statement certifying accuracy of information contained in the completed Cadet applications.

2. Are all participants physically and mentally capable of participating in the Program?

Ref: DoDI 1025.8, paragraph 4.10.7 and paragraph 6.3.1.2; CP 3-1, Chapter II, paragraph

6A; and NGYCP-CA, Section 201, paragraph e(3)(f).

Inspected Item: Questions 2a–2c below.

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2a. Have all participants received a physical examination?

Ref: NGYCP-CA, Section 1-4, paragraph a(4); and DoDI 1025.8, paragraph 6.3.1.2.

Inspected Item: Review completed Cadet applications for copy of physical exam.

Reviewed 10 Cadet records from Classes 29 and 30. All contained physical exam forms.

2b. Has the Program made reasonable accommodations for participants with physical or other disabilities?

Ref: DoDI 1025.8, paragraph 4.10.7; CP 3-1, Chapter II, paragraph 6A; and NGYCP-CA, Section 201, paragraph e(3)(g).

Inspected Item: Interview medical Staff or Director and review Medical or Selection

Procedures SOP.

2c. Does the Program use pregnancy testing as part of the screening and selection process for Program participation?

Ref: NGYCP-CA Section 1-18

Inspected Item: Interview Medical Staff or Director and review Medical or Selection

Procedures SOP.

3. Has the Program communicated to all participants (Cadets) that while receiving training under the ChalleNGe Program that they are neither federal employees nor members of the National Guard except under certain provisions of the law?

Ref: DoDI 1025.8, paragraph 6.4 and NGYCP-CA, Section 201, paragraph e(4).

Inspected Item: Questions 3a–3f below.

3a. Has the Program communicated to all participants (Cadets) that they shall be considered federal employees for the purposes of compensation for work injuries?

Ref: DoDI 1025.8, paragraph 6.4.1.1 and NGYCP-CA, Section 201, paragraph e(4)(b).

Inspected Item: Review Program notification process.

3b. Are Cadets processed through the Federal Employees Compensation Act (FECA) when injuries are sustained as a result of participation in the Program?

Ref: NGYCP-CA, Section 1-4, paragraph a(5)(a).

3c. Has the Program communicated to all participants (Cadets) that they shall be considered federal employees relating to the liability of the United States for tortious conduct of employees of the United States?

Ref: DoDI 1025.8, paragraph 6.4.1.2 and NGYCP-CA, Section 201, paragraph e(4)(b).

3d. Has the Program communicated to all participants (Cadets) that they shall not be considered to be in the performance of duty while not at the assigned location of training or other activity authorized in accordance with the Program agreement except when the participant is traveling to or from the location or is on pass from that training or other activity?

Ref: DoDI 1025.8, paragraph 6.4.2.1 and NGYCP-CA, Section 201, paragraph e(4)(c).

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3e. Has the Program communicated to all participants (Cadets) that in computing compensation benefits for disability or death, the monthly pay of a participant (Cadet) shall be deemed that received under the entrance salary for a grade GS-2 Federal employee?

Ref: DoDI 1025.8, paragraph 6.4.2.2 and NGYCP-CA, Section 201, paragraph e(4)(d).

3f. Has the Program communicated to all participants (Cadets) that the entitlement of a person to receive compensation for a disability shall begin on the day following the date that the person’s participation in the Program is terminated?

Ref: DoDI 1025.8, paragraph 6.4.2.3 and NGYCP-CA, Section 201, paragraph e(4)(e).

Organization

4. Does the Program meet the mandatory minimum Staffing levels?

Note: Mandatory minimum Staffing levels shall be determined by taking the authorized

Staffing by graduation target totals, subtracting the discretionary support Staff authorized for that graduation target total, and multiplying that number by 0.8.

Ref: NGYCP-CA, Section 1-26, paragraph a, Note 17.

Inspected Item: Perform calculation from Note 17 to determine mandatory minimum staffing level.

The lowest authorized staffing level in the Cooperative Agreement is 39 for a target of 75 graduates (80% of 49). Starting in FY16, XX's graduation target was reduced to 60 and currently employs 39 staff members.

N/A

5. If the Program is not meeting mandatory minimum Staffing requirements was prior written approval from the Program Office (NG-J1-AY) received?

Ref: NGYCP-CA, Section 1-26, paragraph a, Note 17.

Inspected Item: Review approval authorization from the Program Office.

Program meets the mandatory minimum staffing level.

6. Are all Program personnel civilian employees of the State or employed under contract with the state?

Ref: DoDI 1025.8, paragraph 6.3.2.1 and NGYCP-CA, Section 201, paragraph f(1).

Inspected Item: Personnel Records.

7. Does the Program Staff have comparable professional qualifications as state employees or contract personnel in similar positions?

Ref: DoDI 1025.8, paragraph 6.3.2.2 and NGYCP-CA, Section 201, paragraph f(3).

Inspected Item: Personnel Records.

8. Is staffing in full time direct support of the ChalleNGe Program mission and requirements?

Ref: NGYCP-CA, Section 1-9, paragraph b.

Inspected Item: Review staffing model/organizational chart.

9. Are personnel functioning as support staff in any way slotted against a Cadre Staffing position?

(Note: Answer should be “NO”).

Ref: NGYCP-CA, Section 1-9, paragraph d.

Inspected Item: Review Personnel files and staffing model.

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10. Are temporary hires employed for less than six months?

Ref: NGYCP-CA, Section 1-9, paragraph c.

Inspected Item: Review personnel files.

Program does not have any temporary hires.

11. Are temporary hires filling deployed military member positions employed for only the period of deployment including the military member’s leave upon return from deployment?

Inspected Item: Review personnel files.

Program has not hired temporary personnel to fill deployed military member positions.

12. Are direct hire, contract, or temporary hire personnel only used during the

Acclimation Period to fill any Cadre Staff positions without slotting them against the

Staffing Model in the Operations/Cadre Staff section?

Ref: NGYCP-CA, Section 1-9, paragraph d.

Inspected Item: Review Personnel files and Staffing model.

Program does not hire temporary personnel during the Acclimation Period.

13. Are personnel filling positions performing the stated job function?

Inspected Item: Interview Staff and compare to Staffing model.

14. Has the Program Director verified that all State Youth ChalleNGe Program employees undergo a background check IAW NGB PARC Guard Knowledge Online?

Note: <https://gkoportal.ng.mil/ngb/STAFF/D01/D01/S02/SitePages/Home.aspx>

Ref: Chief National Guard Bureau Instruction 9350.01, Enclosure A, paragraph 9.k.

Inspected Item: Review the background check results State Youth ChalleNGe Program employees.

15. Has the Program reviewed Staff information on a monthly basis as required?

Ref: NGYCP-CA, Section 1-9, paragraph f.

Inspected Item: Questions 15a–15d below.

15a. Has the Program reviewed Staff hires?

Inspected Item: Contract or HR document reflecting the four most recent hires.

15b. Has the Program reviewed Staff terminations?

Inspected Item: Contract or HR document reflecting the four most recent terminations.

15c. Has the Program reviewed position changes?

Ref: NGYCP-CA, Section 1-9, paragraph f

Inspected Item: Contract or HR document reflecting the four most recent position changes.

15d. Has the Program reviewed any other pertinent information as it relates to Staff structure, for example, temporary personnel or Cadet Peer Mentors?

Inspected Item: Contract or HR document.

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16. After the monthly review, is the Staff information updated in a data management system?

Inspected Item: Data management system.

17. Has the Program assigned a Staff member (Training Officer) responsible for ensuring all staff members attend the required training offered by the Program Office (NG-J1-

AY)?

Ref: CP 3-1, Chapter II, paragraph 8B.

Inspected Item: Check Staff assignments and duties or assignment memorandum.

18. Has the Program Director attended training to acquire needed skills and knowledge of total Program management and networks to assist in assessing the effectiveness of their Programs?

Ref: NGYCP-CA, Section 1-9, paragraph g; CP-1, Chapter II, paragraph 2.B.3; and CP-3-1, Chapter II

Inspected Item: Questions 18a–18b below.

18a. Has the Program Director attended the “New Directors Workshop” within the first year of assuming the Program Directors position?

Ref: NGYCP-CA, Section 1-9, paragraph g(1)(b) and CP-1, Chapter II, paragraph 2.B.3.a.1.

Inspected Item: Review Program Director’s training file.

18b. Has the Program Director attended an Annual ChalleNGe Workshop?

Ref: NGYCP-CA, Section 1-9, paragraph g(1)(a) and CP-1, Chapter II, paragraph 2.B.3.a.2.

Inspected Item: Review Program Director’s training file.

19. Have all ChalleNGe Staff (Cadre, RPM, instructors, supervisors, etc.) attended a

Basic Course within a year of being hired?

Ref: NGYCP-CA, Section 1-9, paragraph g(2); Section 1-11, paragraph b(1)(a); and CP-1, Chapter II, paragraph 2.B.1.

Inspected Item: Program training records.

20. Have all ChalleNGe Staff (Cadre, RPM, instructors, supervisors, etc.) attended their function-specific course within the first two years of hire?

Ref: NGYCP-CA, Section 1-9, paragraph g(2); Section 1-11, paragraph b(1)(b); and CP-1, Chapter II, paragraph 2.B.

Inspected Item: Questions 20a–20e below.

20a. Have Staff members assigned as Cadre completed the Cadre Course?

Ref: CP-1, Chapter II, paragraph 2.B.2.a. and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Training records of Cadre staff.

20b. Have Staff members assigned as Counselors completed the Counselors Course?

Ref: CP-1, Chapter II, paragraph 2.B.2.b. and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Training records of Counseling staff.

Two staff members requires the Counselors Course. Inspected but not included in the overall inspection team/rating.

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20c. Have Staff members assigned as Recruiters completed the Recruiters Course?

Ref: CP-1, Chapter II, paragraph 2.B.2.c. and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Training records of Recruiting staff.

Inspected but not included in the overall inspection team/rating.

20d. Have Staff members assigned as Educators completed the Educators Course?

Ref: CP-1, Chapter II, paragraph 2.B.2.d. and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Training records of Education staff.

20e. Have Staff members assigned as Post-Residential Staff completed the Post-

Residential Course?

Ref: CP-1, Chapter II, paragraph 2.B.2.e. and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Training records of Post-Residential Staff.

21. Have Staff members that are in supervisory positions completed the Supervisors

Course within 12 months of assuming the supervisory position?

Ref: NGYCP-CA, Section 1-11, paragraph b(2)(c).

Inspected Item: Training records of Supervisory staff.

22. Have all ChalleNGe Staff (Cadre, Counselors, Recruiters, Educators, Post-

Residential Staff and Supervisors) attended their refresher function-specific course once each three calendar years?

Ref: CP 3-1, Chapter II, paragraph 8.B and NGYCP-CA, Section 1-11, paragraph b(1)(b).

Inspected Item: Staff training records.

Ten staff members require their function-specific course. Inspected but not included in the overall inspection team/rating.

23. Have Staff members completed in-house Staff training?

Ref: CP 3-1, Chapter II, paragraph 8.D.

Inspected Item: Questions 23a–23c below.

23a. Have Staff members completed CPR/first aid training?

Inspected Item: Staff Training Roster.

Systemic: Five staff members require CPR/First Aid.

23b. Have Staff members completed gang awareness training?

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23c. Have Staff members completed conflict resolution training?

Note: Completion of Non-Violent Crisis Intervention Training fulfills this requirement.

Systemic: Four staff members require Conflict Resolution (CPI) training.

24. Is the Program in compliance with State policies requiring mandated reporting?

Note: Because the laws on these issues vary from state to state, it is critical for Programs to consult with their State’s servicing legal authority to develop policy and training in these areas.

Ref: Recruiting, Placement and Mentoring Operations Manual, Mandated Reporters, Page 26

Inspected Item: Review the State’s mandatory reporting requirements along with the

Program’s local policy, training syllabus, and training records.

25. Are volunteers trained on the responsibilities that arise when they become aware of abuse or similar concerns?

Note: The training syllabus should include the following required incidents related to children: Any abuse-sexual, physical, or emotional; Any unsafe situation; Suicide threats;

and, Plans to commit a crime.

Ref: Recruiting, Placement and Mentoring Operations Manual, Mandated Reporters, Page 26

Inspected Item: Review the State’s mandatory reporting requirements along with the

Program’s local policy, training syllabus, and training records.

Administrative Requirements

26. Did the Program adequately respond to the Report of Inspection?

Ref: NGYCP-CA, Section 1-2, paragraph b(5) and Section 1-3 and Report Of Inspection

Memorandum from Chief, NG-J1-AY

Inspected Item: Questions 26a - 26d below.

26a. Was a Corrective Action Plan developed?

Ref: NGYCP-CA, Section 1-2, paragraph b(5) and Section 1-3 and Report Of Inspection

Inspected Item: Review completed Corrective Action Plan.

26b. Was the Corrective Action Plan submitted on time?

Note: 30 days from receipt of ROE Memorandum from Chief, NG-J1-AY for significant findings or 60 days from receipt of ROE Memorandum from Chief, NG-J1-AY for ROE’s without significant findings.

Ref: NGYCP-CA, Section 1-2, paragraph b(5) and Section 1-3, and Report Of Inspection

Inspected Item: Review transmittal email or mail receipt.

26c. Did the Corrective Action Plan address each area of non-compliance from the

Report of Evaluation with specific strategies, updated policies, detailed procedures, etc?

Ref: NGYCP-CA, Section 1-2, paragraph b(5) and Section 1-3, and Report Of Inspection

Inspected Item: Review completed Corrective Action Plan.

Performance component of the inspection was not addressed in the Corrective Action Plan.

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26d. Did each strategy from the Corrective Action Plan resolve the issue of non-compliance?

Ref: NGYCP-CA, Section 1-2, paragraph b(5) and Section 1-3, and Report Of Inspection

Inspected Item: Compare NO-GOs from previous assessment.

Strategies implemented to correct noncompliance issues associated with insufficient