2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-003: Material weakness in Internal Control / Material 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 $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445.
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.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Eligibility
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: The WIOA 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 that all eligibility related conditions were met for each participant selected for testing.
Context: The Consortium was unable to locate documentation for some elements of eligibility requirements for 5 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: All eligibility related conditions for some participants receiving benefits could not be confirmed. Therefore, benefits may have been paid to participants whose eligibility may be challenged as not all the eligibility related conditions were documented.
Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to ensure 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 established a process for ensuring documentation is properly saved and management has and will sign off on those documents’ accuracy.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-005: Significant Deficiency in Internal Control / Immaterial Noncompliance – Reporting (repeat comment)
Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278)
Criteria: Per 2 CFR 200.403 (g), “Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal awards:” and “(g) Be adequately documented.” Policy Issuances for the WIOA programs state that all reporting of expenditures of the funds provided through these grants must be reported to Workforce Development on a quarterly basis.
Condition: During our review it was noted that documentation supporting reports filed by the Consortium were not maintained by management.
Context: Management of the Consortium did not retain supporting documentation used to complete the reports at the time they were prepared.
Cause: Management oversight.
Effect: Unable to determine that required reports were based on accurate, supporting documentation.
Recommendation: The Consortium should adopt policies and procedures that require that they maintain adequate documentation for quarterly and final close out reports.
Views of Responsible
Officials: We agree with the finding. As we work towards developing our procedures, we are currently developing a list of required documentation as mandatory sourcing for quarterly reports.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.
2023-002: Material Weakness in Internal Control / Material Noncompliance – Eligibility (repeat comment)
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.