As BJA’s technical assistance provider for the Prison Industry Enhancement Certification Program (PIECP), NCIA makes available the following types of technical assistance to current PIECP managers and to others interested in PIECP:
1. Applying for PIECP Certification
Jurisdictions interested in applying for PIECP certification are encouraged to contact NCIA for assistance in completing BJA’s application materials. NCIA can connect potential applicants with other jurisdictions that have successfully navigated particular issues related to PIECP and work with the applicant as it develops appropriate policies and procedures to meet BJA’s requirements.
2. CAC Designation and Re-Designation
PIECP managers are invited to check with NCIA when considering whether or not a proposed new prison industries product/service should be designated under PIE as a Cost Accounting Center.
PIECP managers also are invited to check with NCIA if circumstances change for a given CAC, triggering concerns that a new designation might be required. For example, if the CAC location is changed, or if there is a change in the product being manufactured, must the CAC be re-designated?
3. Wage Documentation Review
To ensure that wages are meeting BJA’s wage requirements, PIECP managers may request a wage practice review. Determining the 10th percentile wage, training wages and times, and back wage calculations are important components for PIECP managers to understand. NCIA will assist the PIECP manager in comparing BJA’s requirements with the State’s DES responses to requests for wage data, and the Certificate Holder’s approach to wage policy. By taking advantage of this additional wage setting check, the Certificate Holder is more likely to avoid the need for back wage payments due to misinterpretation of PIECP wage requirements.
Once a CAC has been operating for a year, BJA does not require that annual wage update requests to the state department of economic security include a separate request for a displacement determination. However, PIECP managers may wish to consider making a displacement request for other reasons. NCIA can share its knowledge of approaches taken by other Certificate Holders facing similar decisions.
5. Analyzing Worker’s Compensation Requirements Under PIECP
As a general matter, while Worker’s Compensation benefits for PIECP inmate workers must be comparable to those provided to private sector counterparts, procedures need not be exactly duplicative, and while types of coverage musts be comparable, they may not need to be identical. The burden is on the Certificate Holder to show that the benefits are comparable to those made available to comparable private sector workers. NCIA offers its assistance in analyzing these questions for PIECP managers.
PIECP managers must determine what deductions they will make for the earnings of PIECP workers. NCIA can help in explaining allowable deductions under BJA’s Guideline.
7. Understanding the NEPA Requirement
PIECP Certificate Holders are required to meet the requirements of the National Environmental Policy Act, but it is not always clear what triggers the need for a request for categorical exclusion from NEPA requirements. NCIA can help the PIECP Manager to analyze the conditions under which a CAC would meet the necessary standards for compliance.
8. Assessment Preparation
BJA asks NCIA to assess PIECP Certificate Holders for compliance with PIECP requirements on a regular basis. PIECP managers who are uncertain of their PIECP operations will meet compliance requirements, or if their policies or procedures might conflict with Federal PIECP requirements, can contact NCIA for suggested approaches. In the event of non-compliance findings during an assessment, NCIA will work with the Certificate Holder and BJA to develop a plan to resolve any non-compliance issues.
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