Cluster name: Forest Service Schools and Roads Cluster Assistance Listings number and name: 10.665 Schools and Roads?Grants to States Award number and year: Not applicable Federal agency: U.S. Department of Agriculture Compliance requirements: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal law, the County?s Public Health Services Department did not provide to its resource advisory committee and the public the required 45-day comment period on its proposal to spend its Title III monies prior to spending them. Specifically, the County spent its entire Title III award of $50,417 for wildfire education, prevention, and protection; and search, rescue, and patrol activities without submitting its proposal to its resource advisory committee. Additionally, the Department had already spent $46,506, or 92 percent, of its awarded Title III monies before it provided notice of its proposal to the public, which occurred 10 months later. Effect?Although the County spent its Title III monies for allowable uses, neither the County?s resource advisory committee nor the public had the opportunity to comment on the County?s use of the Title III monies. Cause?The Department reported that they were unaware of the federal law?s requirements and, therefore, did not have written policies and procedures to ensure that it provided its resource advisory committee and the public the required 45-day comment period prior to spending its Title III monies. Criteria?Federal law provides that the County can use Title III monies for allowable uses, such as wildfire education, prevention, and protection; and search, rescue, and patrol activities, only after the County provides a 45-day comment period on its proposed spending. Specifically, the County is required to submit its proposed use of the monies to its resource advisory committee, while also publishing in a public notice for comment, allowing 45-days for comments on its proposal before spending the monies (16 U.S.C. ?7142[b]). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Develop and implement written policies and procedures for submitting its proposal for spending Title III monies to its resource advisory committee, publishing public notice of the proposal for comment, and spending the monies on allowable uses only after the required 45-day comment period. 2. Ensure that its employees responsible for administering the program are aware of the federal law?s requirement and are trained on the Department?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Award number and years: SLFRP2144, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to County policies and procedures, the County?s Finance Department did not review and approve all 4 federal program reports (progress reports), including 1 interim and 3 project and expenditure reports, before submitting them to the federal agency. Specifically, the Department was advanced $21,545,688 of program monies, and of this amount, the Department reported expenditures totaling $10,035,175 in progress reports as of June 30, 2022. However, the Department did not perform an independent review and approval of these required progress reports to ensure the $10,035,175 of reported expenditures was accurate, agreed to County records, and contained only allowable expenditures. Effect?Although we noted no errors on these reports, there is an increased risk that the Department may not prevent or detect and correct errors on reports it submits to the federal agency, which relies on them to effectively monitor the County?s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program?s success. Cause?While the Department was aware of County policies and procedures requiring it to perform an independent review and approval of the program?s reports before submitting them to the federal agency, the Department reported that it prioritized identifying allowable projects for the program and forgot to implement a process to review and approve the interim report and first 2 project and expenditure reports. Further, the Department reported that while it reviewed the third and final project and expenditure report, it did not maintain documentation of that review and approval. Criteria?The County?s policies and procedures require departments to perform an independent review and approval of all federal award transactions and reports for accuracy before submitting them to the federal agency (Navajo County. [2019]. Fiscal Policy Manual, Section 4.9). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should follow the County?s policies and procedures requiring it to perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Forest Service Schools and Roads Cluster Assistance Listings number and name: 10.665 Schools and Roads?Grants to States Award number and year: Not applicable Federal agency: U.S. Department of Agriculture Compliance requirements: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal law, the County?s Public Health Services Department did not provide to its resource advisory committee and the public the required 45-day comment period on its proposal to spend its Title III monies prior to spending them. Specifically, the County spent its entire Title III award of $50,417 for wildfire education, prevention, and protection; and search, rescue, and patrol activities without submitting its proposal to its resource advisory committee. Additionally, the Department had already spent $46,506, or 92 percent, of its awarded Title III monies before it provided notice of its proposal to the public, which occurred 10 months later. Effect?Although the County spent its Title III monies for allowable uses, neither the County?s resource advisory committee nor the public had the opportunity to comment on the County?s use of the Title III monies. Cause?The Department reported that they were unaware of the federal law?s requirements and, therefore, did not have written policies and procedures to ensure that it provided its resource advisory committee and the public the required 45-day comment period prior to spending its Title III monies. Criteria?Federal law provides that the County can use Title III monies for allowable uses, such as wildfire education, prevention, and protection; and search, rescue, and patrol activities, only after the County provides a 45-day comment period on its proposed spending. Specifically, the County is required to submit its proposed use of the monies to its resource advisory committee, while also publishing in a public notice for comment, allowing 45-days for comments on its proposal before spending the monies (16 U.S.C. ?7142[b]). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Develop and implement written policies and procedures for submitting its proposal for spending Title III monies to its resource advisory committee, publishing public notice of the proposal for comment, and spending the monies on allowable uses only after the required 45-day comment period. 2. Ensure that its employees responsible for administering the program are aware of the federal law?s requirement and are trained on the Department?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirement: Earmarking Questioned costs: $27,180 Condition?Contrary to federal regulation, the County's Workforce Innovation and Opportunity Act (WIOA) Department failed to ensure that it spent the required 20 percent, or $68,164, of WIOA Youth Activities monies earmarked to provide in-school and out-of-school youth with paid and unpaid work experiences from April 2020 through June 2022. Instead, the County spent only 11 percent, or $40,985, of the required 20 percent and spent the remaining 9 percent, or $27,180, for other youth activities, such as education and youth development. Effect?County youth did not receive $27,180 of paid and unpaid work experience services that the federal program intended. Also, the Department may have received $27,180 in federal program monies that it was not entitled to. Cause?The Department used a tracking mechanism to accurately report its paid and unpaid work experiences spending throughout the fiscal year but did not properly monitor its WIOA Youth Activities spending to ensure the 20 percent earmarking requirement was met. Further, the Department did not include in its policies and procedures a requirement for its WIOA Youth Activities program to ensure it developed an effective strategy to recruit and retain qualified in-school and out-of-school youth who would benefit from paid and unpaid work experiences, monitored its paid and unpaid work experience expenditures throughout the award period, and adjusted spending when work experience participation was lower than expected. Criteria?Federal regulation requires the Department to earmark and spend no less than 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. Additionally, federal regulation also requires the Department to monitor such expenditures and report them to the pass-through grantor monthly throughout the award period to ensure it is spending the monies in a timely manner to meet the earmarking requirement (20 Code of Federal Regulations [CFR] ?681.590). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should: 1. Spend no less than the required 20 percent of its WIOA Youth Activities monies to provide in-school and out-of-school youth with paid and unpaid work experiences. 2. Include a process in its WIOA Youth Activities program?s policies and procedures to: a. Develop an effective strategy to recruit and retain qualified in-school and out-of-school youth who will benefit from the paid and unpaid work experience the program provides. b. Monitor its paid and unpaid work experiences spending throughout the award period. c. Adjust spending to meet the earmarking requirement if work experience participation is lower than expected. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Award number and years: SLFRP2144, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to County policies and procedures, the County?s Finance Department did not review and approve all 4 federal program reports (progress reports), including 1 interim and 3 project and expenditure reports, before submitting them to the federal agency. Specifically, the Department was advanced $21,545,688 of program monies, and of this amount, the Department reported expenditures totaling $10,035,175 in progress reports as of June 30, 2022. However, the Department did not perform an independent review and approval of these required progress reports to ensure the $10,035,175 of reported expenditures was accurate, agreed to County records, and contained only allowable expenditures. Effect?Although we noted no errors on these reports, there is an increased risk that the Department may not prevent or detect and correct errors on reports it submits to the federal agency, which relies on them to effectively monitor the County?s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program?s success. Cause?While the Department was aware of County policies and procedures requiring it to perform an independent review and approval of the program?s reports before submitting them to the federal agency, the Department reported that it prioritized identifying allowable projects for the program and forgot to implement a process to review and approve the interim report and first 2 project and expenditure reports. Further, the Department reported that while it reviewed the third and final project and expenditure report, it did not maintain documentation of that review and approval. Criteria?The County?s policies and procedures require departments to perform an independent review and approval of all federal award transactions and reports for accuracy before submitting them to the federal agency (Navajo County. [2019]. Fiscal Policy Manual, Section 4.9). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The Department should follow the County?s policies and procedures requiring it to perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.