45 C.F.R. part 75 subpart D, section 75.305(b) states for non-Federal entities other than states, 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 whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.
Ohio Admin. Code § 5101:9-7-03(B) states that when a County Department of Job and Family Services (CDJFS) is funded on a reimbursement basis, program costs are paid by local funds before reimbursement is requested. When funds are drawn in advance, the CDJFS shall follow procedures to minimize the time elapsing between the transfer of funds from the state and local disbursement. Disbursements to a CDJFS administering federal programs shall cover allowable expenditures consistent with federal and state regulations.
(1) Requests for cash draws may be submitted weekly and are processed by the Ohio department of job and family services (ODJFS) in six working days. In accordance with 45 C.F.R. part 75 subpart D, section 75.305, cash drawn in advance must be limited to the minimum amount needed for actual, immediate requirements. The CDJFS shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten day average for all federal funding.
(2) Cash drawn shall be traceable to program expenditures sufficient to establish such funds have not been used in violation of the restrictions and prohibitions of applicable rules and regulations. The accounting systems of the CDJFS shall support internal controls necessary to insure federal grants and state funds remain separated on a grant, program, or project basis.
Ohio Admin. Code § 5101:9-7-03(C) states (1) the county finance information system (CFIS) calculates the average number of days of cash on hand on an individual grant basis. This information is based on expenditures and cash draws reported in CFIS in accordance with rule 5101:9-7-29 of the Administrative Code and reflected in the CFIS over/under report. The average number of days of cash on hand is calculated as follows:
(a) The cash on hand amount is calculated by deducting the reported expenditures over the lifetime of the funding source, up to the budgeted amount from the total amount of cash draws over the lifetime of the funding source;
(b) The daily average expenditure amount is calculated by dividing the total reported expenditures by the number of calendar days the funding has been available; and (c) The average number of days of cash on hand is calculated by dividing the cash on hand from paragraph (C)(1)(a) of this rule by the average daily expenditures in paragraph (C)(1)(b) of this rule.
(2) At the end of each quarter, the CDJFS shall review the CFIS cash on hand report to ensure compliance with paragraph (B)(1) of this rule.
(a) If an event, beyond the reasonable control of the CDJFS, results in noncompliance with the cash management requirements, the CDJFS shall document the event.
(b) If circumstances resulting in the noncompliance are caused by internal control deficiencies or operational processes, the CDJFS shall document the steps implemented to avoid a reoccurrence.
(3) Continued non-compliance may result in ODJFS restricting the agency's draws to ensure the cash management practices of the CDJFS are in compliance with paragraph (B)(1) of this rule.
The Logan County Department of Job and Family Services had 1 of the 4 quarters during fiscal year 2023 where the average cash on hand exceeded ten days for the Social Services Block Grant funding. Due to lack of internal controls over cash management, the County had over 167 days of cash on hand.
The failure to comply with the cash management requirements per the federal C.F.R. and Ohio Administrative Code could result in the Ohio Department of Job and Family Services restricting the agency's draws to ensure the cash management practices are in compliance with the requirements or a loss of grant funding. The Logan County Department of Job and Family Services should review the policies and procedures in place for drawing down Federal grant monies to help ensure only cash needed for immediate use is requested. Furthermore, the drawdowns should be limited to cover transactions expected to be expended within ten days.
45 C.F.R. part 75 subpart D, section 75.305(b) states for non-Federal entities other than states, 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 whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.
Ohio Admin. Code § 5101:9-7-03(B) states that when a County Department of Job and Family Services (CDJFS) is funded on a reimbursement basis, program costs are paid by local funds before reimbursement is requested. When funds are drawn in advance, the CDJFS shall follow procedures to minimize the time elapsing between the transfer of funds from the state and local disbursement. Disbursements to a CDJFS administering federal programs shall cover allowable expenditures consistent with federal and state regulations.
(1) Requests for cash draws may be submitted weekly and are processed by the Ohio department of job and family services (ODJFS) in six working days. In accordance with 45 C.F.R. part 75 subpart D, section 75.305, cash drawn in advance must be limited to the minimum amount needed for actual, immediate requirements. The CDJFS shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten day average for all federal funding.
(2) Cash drawn shall be traceable to program expenditures sufficient to establish such funds have not been used in violation of the restrictions and prohibitions of applicable rules and regulations. The accounting systems of the CDJFS shall support internal controls necessary to insure federal grants and state funds remain separated on a grant, program, or project basis.
Ohio Admin. Code § 5101:9-7-03(C) states (1) the county finance information system (CFIS) calculates the average number of days of cash on hand on an individual grant basis. This information is based on expenditures and cash draws reported in CFIS in accordance with rule 5101:9-7-29 of the Administrative Code and reflected in the CFIS over/under report. The average number of days of cash on hand is calculated as follows:
(a) The cash on hand amount is calculated by deducting the reported expenditures over the lifetime of the funding source, up to the budgeted amount from the total amount of cash draws over the lifetime of the funding source;
(b) The daily average expenditure amount is calculated by dividing the total reported expenditures by the number of calendar days the funding has been available; and (c) The average number of days of cash on hand is calculated by dividing the cash on hand from paragraph (C)(1)(a) of this rule by the average daily expenditures in paragraph (C)(1)(b) of this rule.
(2) At the end of each quarter, the CDJFS shall review the CFIS cash on hand report to ensure compliance with paragraph (B)(1) of this rule.
(a) If an event, beyond the reasonable control of the CDJFS, results in noncompliance with the cash management requirements, the CDJFS shall document the event.
(b) If circumstances resulting in the noncompliance are caused by internal control deficiencies or operational processes, the CDJFS shall document the steps implemented to avoid a reoccurrence.
(3) Continued non-compliance may result in ODJFS restricting the agency's draws to ensure the cash management practices of the CDJFS are in compliance with paragraph (B)(1) of this rule.
The Logan County Department of Job and Family Services had 1 of the 4 quarters during fiscal year 2023 where the average cash on hand exceeded ten days for the Social Services Block Grant funding. Due to lack of internal controls over cash management, the County had over 167 days of cash on hand.
The failure to comply with the cash management requirements per the federal C.F.R. and Ohio Administrative Code could result in the Ohio Department of Job and Family Services restricting the agency's draws to ensure the cash management practices are in compliance with the requirements or a loss of grant funding. The Logan County Department of Job and Family Services should review the policies and procedures in place for drawing down Federal grant monies to help ensure only cash needed for immediate use is requested. Furthermore, the drawdowns should be limited to cover transactions expected to be expended within ten days.
45 CFR § 1356.60(a)(1)(i) states "Federal financial participation (FFP) is available to title IV-E agencies under an approved title IV-E plan for allowable costs in expenditures for foster care maintenance payments as defined in section 475(4) of the Act, made in accordance with §§ 1356.20 through 1356.30, section 472 of the Act, and, for a Tribal title IV-E agency, section 479B of the Act..." Ohio Admin. Code § 5101:2-47-11 states:
"(A) In order to be reimbursed for Title IV-E foster care maintenance (FCM) costs when a child is placed in a children’s residential center (CRC), group home, maternity home, residential parenting facility, or with a parent in a substance use disorder (SUD) residential facility as defined in rule 5101:2-1-01 of the Administrative Code a JFS 02911 "Title IV-E Single Cost Report" as described in rule 5101:2-47-26.1 of the Administrative Code is to be submitted to the Ohio department of job and family services annually. Agencies certified prior to October 1, 2020 have until October 1, 2024 to become compliant with the requirements related to meeting qualified residential treatment program (QRTP) standards.
(B) If a JFS 02911 cost report has been approved for children placed in a CRC, group home, maternity home, residential parenting facility or SUD residential facility, two Title IV-E reimbursement ceiling amounts are calculated and rounded to the nearest dollar.
(1)The FCM reimbursement ceiling amount is based on reported and allowable FCM costs.
(2)The Title IV-E administration reimbursement ceiling amount is based on reported allowable Title IV-E administration costs.
(C) Reimbursement to the Title IV-E agency for children placed in a CRC, group home, maternity home, residential parenting facility, or SUD residential facility is based on the lesser of:
(1)The FCM reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for foster care maintenance.
(2)The administration reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for administration."
Furthermore, Ohio Admin. Code § 5101:2-47-11(G) states:
"To receive reimbursement a Title IV-E agency processing their payments and seeking reimbursement from Ohio statewide automated child welfare information system (SACWIS) is to:
(1)Record placement, service authorization and placement cost information for each child.
(2)Generate a payment by creating a payment request and sending the payment information to the county auditor for payment.
(3)Disburse payments through the county auditor at any point during a month. These payments will be reimbursed during the monthly reimbursement process conducted by ODJFS on the first business day of the following month.
(4)Access reports to review all itemized reimbursements and assure the reimbursements are accurate."
The Children's Services Department completed the required reporting within the SACWIS system; however, due to lack of controls over review of the system for accuracy, the August 2023 reimbursement was overpaid by 12 care days for one child. The SACWIS report was used for federal reimbursement to the Children's Services Department and thus resulted in $1,628 more in reimbursements than the department was entitled based on the provider invoices.
Failure to properly report number of care days can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The Logan County Children's Services Department should implement policies and procedures to ensure the accuracy of data input within the SACWIS system.
45 C.F.R. part 75 subpart D, section 75.305(b) states for non-Federal entities other than states, 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 whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.
Ohio Admin. Code § 5101:9-7-03(B) states that when a County Department of Job and Family Services (CDJFS) is funded on a reimbursement basis, program costs are paid by local funds before reimbursement is requested. When funds are drawn in advance, the CDJFS shall follow procedures to minimize the time elapsing between the transfer of funds from the state and local disbursement. Disbursements to a CDJFS administering federal programs shall cover allowable expenditures consistent with federal and state regulations.
(1) Requests for cash draws may be submitted weekly and are processed by the Ohio department of job and family services (ODJFS) in six working days. In accordance with 45 C.F.R. part 75 subpart D, section 75.305, cash drawn in advance must be limited to the minimum amount needed for actual, immediate requirements. The CDJFS shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten day average for all federal funding.
(2) Cash drawn shall be traceable to program expenditures sufficient to establish such funds have not been used in violation of the restrictions and prohibitions of applicable rules and regulations. The accounting systems of the CDJFS shall support internal controls necessary to insure federal grants and state funds remain separated on a grant, program, or project basis.
Ohio Admin. Code § 5101:9-7-03(C) states (1) the county finance information system (CFIS) calculates the average number of days of cash on hand on an individual grant basis. This information is based on expenditures and cash draws reported in CFIS in accordance with rule 5101:9-7-29 of the Administrative Code and reflected in the CFIS over/under report. The average number of days of cash on hand is calculated as follows:
(a) The cash on hand amount is calculated by deducting the reported expenditures over the lifetime of the funding source, up to the budgeted amount from the total amount of cash draws over the lifetime of the funding source;
(b) The daily average expenditure amount is calculated by dividing the total reported expenditures by the number of calendar days the funding has been available; and (c) The average number of days of cash on hand is calculated by dividing the cash on hand from paragraph (C)(1)(a) of this rule by the average daily expenditures in paragraph (C)(1)(b) of this rule.
(2) At the end of each quarter, the CDJFS shall review the CFIS cash on hand report to ensure compliance with paragraph (B)(1) of this rule.
(a) If an event, beyond the reasonable control of the CDJFS, results in noncompliance with the cash management requirements, the CDJFS shall document the event.
(b) If circumstances resulting in the noncompliance are caused by internal control deficiencies or operational processes, the CDJFS shall document the steps implemented to avoid a reoccurrence.
(3) Continued non-compliance may result in ODJFS restricting the agency's draws to ensure the cash management practices of the CDJFS are in compliance with paragraph (B)(1) of this rule.
The Logan County Department of Job and Family Services had 1 of the 4 quarters during fiscal year 2023 where the average cash on hand exceeded ten days for the Social Services Block Grant funding. Due to lack of internal controls over cash management, the County had over 167 days of cash on hand.
The failure to comply with the cash management requirements per the federal C.F.R. and Ohio Administrative Code could result in the Ohio Department of Job and Family Services restricting the agency's draws to ensure the cash management practices are in compliance with the requirements or a loss of grant funding. The Logan County Department of Job and Family Services should review the policies and procedures in place for drawing down Federal grant monies to help ensure only cash needed for immediate use is requested. Furthermore, the drawdowns should be limited to cover transactions expected to be expended within ten days.
45 C.F.R. part 75 subpart D, section 75.305(b) states for non-Federal entities other than states, 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 whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.
Ohio Admin. Code § 5101:9-7-03(B) states that when a County Department of Job and Family Services (CDJFS) is funded on a reimbursement basis, program costs are paid by local funds before reimbursement is requested. When funds are drawn in advance, the CDJFS shall follow procedures to minimize the time elapsing between the transfer of funds from the state and local disbursement. Disbursements to a CDJFS administering federal programs shall cover allowable expenditures consistent with federal and state regulations.
(1) Requests for cash draws may be submitted weekly and are processed by the Ohio department of job and family services (ODJFS) in six working days. In accordance with 45 C.F.R. part 75 subpart D, section 75.305, cash drawn in advance must be limited to the minimum amount needed for actual, immediate requirements. The CDJFS shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten day average for all federal funding.
(2) Cash drawn shall be traceable to program expenditures sufficient to establish such funds have not been used in violation of the restrictions and prohibitions of applicable rules and regulations. The accounting systems of the CDJFS shall support internal controls necessary to insure federal grants and state funds remain separated on a grant, program, or project basis.
Ohio Admin. Code § 5101:9-7-03(C) states (1) the county finance information system (CFIS) calculates the average number of days of cash on hand on an individual grant basis. This information is based on expenditures and cash draws reported in CFIS in accordance with rule 5101:9-7-29 of the Administrative Code and reflected in the CFIS over/under report. The average number of days of cash on hand is calculated as follows:
(a) The cash on hand amount is calculated by deducting the reported expenditures over the lifetime of the funding source, up to the budgeted amount from the total amount of cash draws over the lifetime of the funding source;
(b) The daily average expenditure amount is calculated by dividing the total reported expenditures by the number of calendar days the funding has been available; and (c) The average number of days of cash on hand is calculated by dividing the cash on hand from paragraph (C)(1)(a) of this rule by the average daily expenditures in paragraph (C)(1)(b) of this rule.
(2) At the end of each quarter, the CDJFS shall review the CFIS cash on hand report to ensure compliance with paragraph (B)(1) of this rule.
(a) If an event, beyond the reasonable control of the CDJFS, results in noncompliance with the cash management requirements, the CDJFS shall document the event.
(b) If circumstances resulting in the noncompliance are caused by internal control deficiencies or operational processes, the CDJFS shall document the steps implemented to avoid a reoccurrence.
(3) Continued non-compliance may result in ODJFS restricting the agency's draws to ensure the cash management practices of the CDJFS are in compliance with paragraph (B)(1) of this rule.
The Logan County Department of Job and Family Services had 1 of the 4 quarters during fiscal year 2023 where the average cash on hand exceeded ten days for the Social Services Block Grant funding. Due to lack of internal controls over cash management, the County had over 167 days of cash on hand.
The failure to comply with the cash management requirements per the federal C.F.R. and Ohio Administrative Code could result in the Ohio Department of Job and Family Services restricting the agency's draws to ensure the cash management practices are in compliance with the requirements or a loss of grant funding. The Logan County Department of Job and Family Services should review the policies and procedures in place for drawing down Federal grant monies to help ensure only cash needed for immediate use is requested. Furthermore, the drawdowns should be limited to cover transactions expected to be expended within ten days.
45 CFR § 1356.60(a)(1)(i) states "Federal financial participation (FFP) is available to title IV-E agencies under an approved title IV-E plan for allowable costs in expenditures for foster care maintenance payments as defined in section 475(4) of the Act, made in accordance with §§ 1356.20 through 1356.30, section 472 of the Act, and, for a Tribal title IV-E agency, section 479B of the Act..." Ohio Admin. Code § 5101:2-47-11 states:
"(A) In order to be reimbursed for Title IV-E foster care maintenance (FCM) costs when a child is placed in a children’s residential center (CRC), group home, maternity home, residential parenting facility, or with a parent in a substance use disorder (SUD) residential facility as defined in rule 5101:2-1-01 of the Administrative Code a JFS 02911 "Title IV-E Single Cost Report" as described in rule 5101:2-47-26.1 of the Administrative Code is to be submitted to the Ohio department of job and family services annually. Agencies certified prior to October 1, 2020 have until October 1, 2024 to become compliant with the requirements related to meeting qualified residential treatment program (QRTP) standards.
(B) If a JFS 02911 cost report has been approved for children placed in a CRC, group home, maternity home, residential parenting facility or SUD residential facility, two Title IV-E reimbursement ceiling amounts are calculated and rounded to the nearest dollar.
(1)The FCM reimbursement ceiling amount is based on reported and allowable FCM costs.
(2)The Title IV-E administration reimbursement ceiling amount is based on reported allowable Title IV-E administration costs.
(C) Reimbursement to the Title IV-E agency for children placed in a CRC, group home, maternity home, residential parenting facility, or SUD residential facility is based on the lesser of:
(1)The FCM reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for foster care maintenance.
(2)The administration reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for administration."
Furthermore, Ohio Admin. Code § 5101:2-47-11(G) states:
"To receive reimbursement a Title IV-E agency processing their payments and seeking reimbursement from Ohio statewide automated child welfare information system (SACWIS) is to:
(1)Record placement, service authorization and placement cost information for each child.
(2)Generate a payment by creating a payment request and sending the payment information to the county auditor for payment.
(3)Disburse payments through the county auditor at any point during a month. These payments will be reimbursed during the monthly reimbursement process conducted by ODJFS on the first business day of the following month.
(4)Access reports to review all itemized reimbursements and assure the reimbursements are accurate."
The Children's Services Department completed the required reporting within the SACWIS system; however, due to lack of controls over review of the system for accuracy, the August 2023 reimbursement was overpaid by 12 care days for one child. The SACWIS report was used for federal reimbursement to the Children's Services Department and thus resulted in $1,628 more in reimbursements than the department was entitled based on the provider invoices.
Failure to properly report number of care days can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The Logan County Children's Services Department should implement policies and procedures to ensure the accuracy of data input within the SACWIS system.