2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
We further noted that 20 CFR section 671.140 states the following as allowable activities:
(a) National emergency grants may provide adjustment assistance for eligible dislocated workers, described at WIA section 173(c)(2) or (d)(2).
(b) Adjustment assistance includes the core, intensive, and training services authorized at WIA sections 134(d) and 173. The scope of services to be provided in a particular project are negotiated between the Department and the grantee, taking into account the needs of the target population covered by the grant. The scope of services may be changed through grant modifications, if necessary.
(c) National emergency grants may provide for supportive services to help workers who require such assistance to participate in activities provided for in the grant. Needs-related payments, in support of other employment and training assistance, may be available for the purpose of enabling dislocated workers who are eligible for such payments to participate in programs of training services. Generally, the terms of a grant must be consistent with Local Board policies governing such financial assistance with formula funds (including the payment levels and duration of payments). However, the terms of the grant agreement may diverge from established Local Board policies, in the following instances: (1) If unemployed dislocated workers served by the project are not able to meet the 13 or 8 weeks enrollment in training requirement at WIA section 134(e)(3)(B) because of the lack of formula or emergency grant funds in the State or local area at the time of dislocation, such individuals may be eligible for needs-related payments if they are enrolled in training by the end of the 6th week following the date of the emergency grant award;
(2) Trade-impacted workers who are not eligible for trade readjustment assistance under NAFTA-TAA may be eligible for needs-related payments under a national emergency grant if the worker is enrolled in training by the end of the 16th week following layoff; and
(3) Under other circumstances as specified in the national emergency grant application guidelines.
(d) A national emergency grant to respond to a declared emergency or natural disaster, as defined at § 671.110(e), may provide short-term disaster relief employment for:
(1) Individuals who are temporarily or permanently laid off as a consequence of the disaster;
(2) Dislocated workers; and
(3) Long-term unemployed individuals.
(e) Temporary employment assistance is authorized on disaster projects that provide food, clothing, shelter and other humanitarian assistance for disaster victims; and on projects that perform demolition, cleaning, repair, renovation and reconstruction of damaged and destroyed structures, facilities and lands located within the disaster area. For such temporary jobs, each eligible worker is limited to no more than six months of employment for each single disaster. The amounts, duration and other limitations on wages will be negotiated for each grant.
(f) Additional requirements that apply to national emergency grants, including natural disaster grants, are contained in the application instructions.
During testing of fiscal year 2021, there were costs charged to this grant that were not supported by invoices. The total amount tested that had no invoice support was $14,615 between 7 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal
Awards (the Schedule) for the period covered by the Consortium’s financial statements which must
include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity
and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or
other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards
expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end
of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule,
and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as
covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal
agent's accounting system operated on a full accrual basis and the federal schedule that was
presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio
Department of Job and Family Services. However, the Consortium was not able to provide support
from the accounting system to reconcile the amounts reported on the Schedule to the accounting
system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon
which we based our testing of the compliance for major federal programs was complete and therefore
we could not pinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding
agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures
which help ensure compliance with grant requirements, including Schedule reporting requirements. The
Consortium should implement a system to track all federal expenditures and related information separately
from other expenditures and report federal expenditures with proper support including, but not limited to,
grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3)
which requires a pass-through entity to impose any additional requirements on the subrecipient
necessary in order for the pass-through entity to meet its own responsibility to the
Federal awarding agency including identification of any required financial and performance
reports. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to
submit the completed quarterly financial statement to the Bureau of County Finance and
Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the
quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to
reconcile any difference between the WIOA local area's financial records and financial data
submitted to BCFTA via CFIS.
The following issues were noted related to the quarterly submissions:
1. The quarterly financial certification for the fourth quarter of calendar year 2018
was not filed until February 13, 2019, the third quarter of calendar year 2020 was
not filed until at least November 17, 2020. Both of these were considered late filings.
2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide system reports from their accounting system that reconciled to the actual financial data
(i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of
undetailed transactions to support the amounts they reported on the financial reports. Then for
2021, they provided nothing to support what was reported.
3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to
provide any support for the amounts they reported as accruals on the certifications.
This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job
and Family Services.
The Consortium should implement procedures to ensure quarterly reports are filed no later than the
tenth calendar day of the second month following the quarter the report represents. In addition,
all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
WIOA, 128 Stat. 1525 et seq. outlines the various allowable activities for this program.
During testing of fiscal year 2021, there were costs charged to the WIOA Cluster that were not supported by invoices. The total amount tested that had no invoice support was $11,484 between 4 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
We further noted that 20 CFR section 671.140 states the following as allowable activities:
(a) National emergency grants may provide adjustment assistance for eligible dislocated workers, described at WIA section 173(c)(2) or (d)(2).
(b) Adjustment assistance includes the core, intensive, and training services authorized at WIA sections 134(d) and 173. The scope of services to be provided in a particular project are negotiated between the Department and the grantee, taking into account the needs of the target population covered by the grant. The scope of services may be changed through grant modifications, if necessary.
(c) National emergency grants may provide for supportive services to help workers who require such assistance to participate in activities provided for in the grant. Needs-related payments, in support of other employment and training assistance, may be available for the purpose of enabling dislocated workers who are eligible for such payments to participate in programs of training services. Generally, the terms of a grant must be consistent with Local Board policies governing such financial assistance with formula funds (including the payment levels and duration of payments). However, the terms of the grant agreement may diverge from established Local Board policies, in the following instances: (1) If unemployed dislocated workers served by the project are not able to meet the 13 or 8 weeks enrollment in training requirement at WIA section 134(e)(3)(B) because of the lack of formula or emergency grant funds in the State or local area at the time of dislocation, such individuals may be eligible for needs-related payments if they are enrolled in training by the end of the 6th week following the date of the emergency grant award;
(2) Trade-impacted workers who are not eligible for trade readjustment assistance under NAFTA-TAA may be eligible for needs-related payments under a national emergency grant if the worker is enrolled in training by the end of the 16th week following layoff; and
(3) Under other circumstances as specified in the national emergency grant application guidelines.
(d) A national emergency grant to respond to a declared emergency or natural disaster, as defined at § 671.110(e), may provide short-term disaster relief employment for:
(1) Individuals who are temporarily or permanently laid off as a consequence of the disaster;
(2) Dislocated workers; and
(3) Long-term unemployed individuals.
(e) Temporary employment assistance is authorized on disaster projects that provide food, clothing, shelter and other humanitarian assistance for disaster victims; and on projects that perform demolition, cleaning, repair, renovation and reconstruction of damaged and destroyed structures, facilities and lands located within the disaster area. For such temporary jobs, each eligible worker is limited to no more than six months of employment for each single disaster. The amounts, duration and other limitations on wages will be negotiated for each grant.
(f) Additional requirements that apply to national emergency grants, including natural disaster grants, are contained in the application instructions.
During testing of fiscal year 2021, there were costs charged to this grant that were not supported by invoices. The total amount tested that had no invoice support was $14,615 between 7 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.