2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”.
Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained.
Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562.
Cause: Management oversight.
Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility
Federal Program: Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: The Temporary Assistance for Needy Families Cluster requires that individuals receiving services meet certain eligibility requirements. Eligibility requirements must comply with specific federal requirements.
Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing.
Context: The Consortium was unable to locate eligibility determinations for 3 of 60 participants selected for testing.
Cause: During the COVID-19 pandemic, selected staff were allowed to work remotely. Consequently, some staff stored eligibility documentation on the local drive of their work computers. As staff left employment, these files were not restored to a network database that is maintained, and accessible, by the Consortium. Therefore, the Consortium was unable to locate some eligibility documentation.
Effect: Eligibility of some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to ineligible participants.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that all eligibility files are stored in a central location and backed up regularly.
Views of Responsible
Officials: We agree with the finding. We recognize the importance of having support documentation for all eligibility determinations. As we continue to strengthen our policies and procedures, we have we have established a process for ensuring documentation is properly saved and management has and will sign off on those documents accuracy.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.
2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Per 2 CFR 200.405, Allocable costs (a) states “a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.”
Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Context: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation which is completed by the accounting staff and communicated to the payroll company. This labor allocation is designed to spread the non-direct charged wage time to the same programs that the employee directly charges time. When an employee changes programs to which their time is directly charged the accounting staff is not notified by the staff but notes the change after the fact during reviews of payroll records. Once the change is noted, a new labor allocation is created and communicated to the payroll company which creates a lag in time whereby amounts of non-direct charged wage time are charged to various programs incorrectly.
Cause: Limitation of current system being utilized to allocate payroll costs.
Effect: Costs charged to the program may be considered unallowable if not allocated in a manner consistent with where the employee actually spends their time.
Recommendation: The Consortium should adopt policies and procedures that require that allocations for labor to align with how the employee actually spends their time.
Views of Responsible
Officials: We agree with the finding. We have addressed the issues within the Consortium to properly allocate non-direct wage time.
2022-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278), Employment Services Cluster (ALN 17.207/17.801), and Temporary Assistance for Needy Families Cluster (ALN 93.558)
Criteria: Policy Issuances for the WIOA Cluster, Employment Services Cluster, and the Temporary Assistance for Needy Families Cluster state that all quarterly financial expenditure reports are due to Workforce Development no later than the 20th calendar day after the end of the calendar quarter. The final close-out report is due to Workforce Development no later than 60 days after the end of the grant period.
Condition: Quarterly reports selected for testing for WIOA Cluster, Employment Services Cluster, and Temporary Assistance for Needy Families Cluster, and final close out reports selected for testing for WIOA Cluster, were submitted after the deadline.
Cause: Management oversight.
Effect: Reports were not filed in a timely manner.
Recommendation: The Consortium should review policies and procedures to ensure that all quarterly and close out reports are filed in a timely manner.
Views of Responsible
Officials: We agree with the finding. Michigan Works! Southeast will continue to work to meet close out deadlines.