We recommend the Assistant Secretary for Employment and Training Administration develop standard operating procedures for discretionary grant programs, which include internal controls resulting in ETA: a. Identifying information needed from grantees for participant level data, quarterly reporting, or program evaluation, prior to submitting the information collection request to OMB; b. Having a complete system and supporting documentation (e.g., user guide, data dictionary, business rules) ready by day one of the grant program with appropriate system controls; c. Obtaining OMB approval numbers for any new information collections prior to collecting information from grantees, verifying the reporting system fields correlate to the approved OMB information collection request, and submitting violations timely to OMB; and d. Conducting compliance reviews prior to awarding grants; using the review results to change applicant scoring or include a condition of award in applicable grants; awarding each grant prior to or on the start of each grantee’s period of performance; and accurately reporting to the public on the grant program.