Audit 308992

FY End
2023-06-30
Total Expended
$1.85M
Findings
18
Programs
7
Year: 2023 Accepted: 2024-06-17

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
400937 2023-001 Material Weakness Yes G
400938 2023-001 Material Weakness Yes G
400939 2023-001 Material Weakness Yes G
400940 2023-001 Material Weakness Yes G
400941 2023-001 Material Weakness Yes G
400942 2023-001 Material Weakness Yes G
400943 2023-001 Material Weakness Yes G
400944 2023-001 Material Weakness Yes G
400945 2023-001 Material Weakness Yes G
977379 2023-001 Material Weakness Yes G
977380 2023-001 Material Weakness Yes G
977381 2023-001 Material Weakness Yes G
977382 2023-001 Material Weakness Yes G
977383 2023-001 Material Weakness Yes G
977384 2023-001 Material Weakness Yes G
977385 2023-001 Material Weakness Yes G
977386 2023-001 Material Weakness Yes G
977387 2023-001 Material Weakness Yes G

Programs

ALN Program Spent Major Findings
17.285 Apprenticeship USA Grants $191,568 - 0
17.225 Unemployment Insurance $85,436 - 0
17.207 Employment Service/wagner-Peyser Funded Activities $64,945 - 0
17.259 Wia Youth Activities $55,942 Yes 1
17.245 Trade Adjustment Assistance $10,282 - 0
17.258 Wia Adult Program $3,264 Yes 1
17.278 Wia Dislocated Worker Formula Grants $2,538 Yes 1

Contacts

Name Title Type
MAM8KFZZ4UL5 Natalie Millhuff-Stang Auditee
7408768548 Natalie Millhuff-Stang Auditor
No contacts on file

Notes to SEFA

Title: Note A – Basis of Presentation Accounting Policies: Expenditures reported on the schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The Board has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Board has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying federal awards expenditures schedule (the schedule) includes the federal grant activity of the Area 20/21 Workforce Development Board (the Board) under programs of the federal government for the fiscal year ended June 30, 2023. The information on this schedule is prepared in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the Board, it is not intended to and does not present the financial position or changes in net position of the Board.
Title: Note C – Subrecipients Accounting Policies: Expenditures reported on the schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The Board has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Board has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The Board passes through certain federal awards received from the Ohio Department of Job and Family Services to other governments or not-for-profit agencies (subrecipients). As Note B describes, the Board reports expenditures of federal awards to subrecipients when paid in cash. As a subrecipient, the Board has certain compliance responsibilities, such as monitoring its subrecipients to help assure that they use these subawards as authorized by laws, regulations, and the provisions of contracts or grant agreements, and that subrecipients achieve the award’s performance goals. The total amount of federal assistance provided to subrecipients by the Board for each federal program is summarized below:Program Title CFDA # Amounts Provided to Subrecipients Subrecipient – Fairfield County Youth 17.259 $32,326 Total Youth 17.259 32,326 Adult 17.258 313,359 WIOA Adult Program-OMJ Resource Sharing 17.258 1,071 Total Adult 17.258 314,430 Dislocated Worker Formula Grants 17.278 127,918 WIOA Dislocated Worker Formula Grants-OMJ Resource Sharing 17.278 833 Total Dislocated Worker 17.278 128,751 Employment Service/Wagner-Peyser Funded Activities 17.207 21,263 Trade Adjustment Assistance 17.245 3,364 Unemployment Insurance-Reemployment Services and Employment Assessments 17.225 85,436 Total Fairfield County $585,570 Program Title CFDA # Amounts Provided to Subrecipients Subrecipient – Pickaway County Youth 17.259 $70,879 Total Youth 17.259 70,879 Adult 17.258 55,904 WIOA Adult Program-OMJ Resource Sharing 17.258 522 Total Adult 17.258 56,426 Dislocated Worker Formula Grants 17.278 18,592 WIOA Dislocated Worker Formula Grants-OMJ Resource Sharing 17.278 406 Total Dislocated Worker 17.278 18,998 Employment Service/Wagner-Peyser Funded Activities 17.207 10,400 Trade Adjustment Assistance 17.245 1,647 Total Pickaway County $158,350 Subrecipient – South Central Ohio JFS Youth 17.259 $157,045 Total Youth 17.259 157,045 Adult 17.258 250,242 WIOA Adult Program-OMJ Resource Sharing 17.258 1,671 Total Adult 17.258 251,913 Dislocated Worker Formula Grants 17.278 137,510 WIOA Dislocated Worker Formula Grants-OMJ Resource Sharing 17.278 1,299 Total Dislocated Worker 17.278 138,809 Employment Service/Wagner-Peyser Funded Activities 17.207 33,282 Trade Adjustment Assistance 17.245 5,271 Total South Central Ohio JFS $586,320 Subrecipient – Pickaway-Ross Career & Technical Center Apprenticeship USA Grants-Pre-Apprenticeship Program 17.285 $75,000 Subrecipient – Hocking Technical College Apprenticeship USA Grants-Pre-Apprenticeship Program 17.285 $110,009

Finding Details

A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.
A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. A minimum of 75 percent of the Youth Activities funds allocated to States and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). Per section 129(c)(4) of the WIOA, not less than 20 percent of the youth program funds shall be used to provide youth participants with paid and unpaid work experiences.The Board did not have procedures in place to monitor and ensure that federal earmarking requirements were being met for any of the programs within the WIOA Cluster. Furthermore, we noted that less than 20 percent of the youth program funds were used to provide youth participants with paid and unpaid work experiences. The Board should have policies and procedures in place, including monitoring, to ensure that earmarking requirements are being met.