31 C.F.R. § 19.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 31 C.F.R. § 19.210 provides that all nonprocurement transactions, as defined in § 19.970 are covered transactions unless listed in § 19.215. 31 C.F.R. § 19.220(b) provides, in part, that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 19.210, and the amount of the contract is expected to equal or exceed $25,000. 31 C.F.R. § 19.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking the EPLS; or (b) collecting a certification from that person if allowed by this rule; or (c) adding a clause or condition to the covered transaction with that person.
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing #21.027, we noted one instance where the County had a payment to a vendor of more than $25,000 and there was no evidence the County checked the EPLS, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the three contracts tested with covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2023.
Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred.
Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the EPLS, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments 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)(1) states the County Departments of Job and Family Services 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.
The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 50 days per review of the CR 502 reports in 2023. Therefore, the cash on hand exceeded the allowable number of days by 40 for the year.
The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.
45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods.
The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays.
In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation.
1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity.
2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed.
3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator.
4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle.
Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours.
The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023:
• Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period.
• Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period.
• One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not.
• Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed.
Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool.
The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.
31 C.F.R. § 19.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 31 C.F.R. § 19.210 provides that all nonprocurement transactions, as defined in § 19.970 are covered transactions unless listed in § 19.215. 31 C.F.R. § 19.220(b) provides, in part, that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 19.210, and the amount of the contract is expected to equal or exceed $25,000. 31 C.F.R. § 19.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking the EPLS; or (b) collecting a certification from that person if allowed by this rule; or (c) adding a clause or condition to the covered transaction with that person.
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing #21.027, we noted one instance where the County had a payment to a vendor of more than $25,000 and there was no evidence the County checked the EPLS, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the three contracts tested with covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2023.
Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred.
Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the EPLS, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods.
The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays.
In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation.
1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity.
2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed.
3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator.
4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle.
Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours.
The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023:
• Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period.
• Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period.
• One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not.
• Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed.
Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool.
The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.
45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments 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)(1) states the County Departments of Job and Family Services 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.
The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 50 days per review of the CR 502 reports in 2023. Therefore, the cash on hand exceeded the allowable number of days by 40 for the year.
The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.
31 C.F.R. § 19.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 31 C.F.R. § 19.210 provides that all nonprocurement transactions, as defined in § 19.970 are covered transactions unless listed in § 19.215. 31 C.F.R. § 19.220(b) provides, in part, that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 19.210, and the amount of the contract is expected to equal or exceed $25,000. 31 C.F.R. § 19.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking the EPLS; or (b) collecting a certification from that person if allowed by this rule; or (c) adding a clause or condition to the covered transaction with that person.
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing #21.027, we noted one instance where the County had a payment to a vendor of more than $25,000 and there was no evidence the County checked the EPLS, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the three contracts tested with covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2023.
Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred.
Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the EPLS, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments 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)(1) states the County Departments of Job and Family Services 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.
The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 50 days per review of the CR 502 reports in 2023. Therefore, the cash on hand exceeded the allowable number of days by 40 for the year.
The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.
45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods.
The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays.
In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation.
1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity.
2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed.
3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator.
4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle.
Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours.
The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023:
• Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period.
• Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period.
• One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not.
• Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed.
Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool.
The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.
31 C.F.R. § 19.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 31 C.F.R. § 19.210 provides that all nonprocurement transactions, as defined in § 19.970 are covered transactions unless listed in § 19.215. 31 C.F.R. § 19.220(b) provides, in part, that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 19.210, and the amount of the contract is expected to equal or exceed $25,000. 31 C.F.R. § 19.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking the EPLS; or (b) collecting a certification from that person if allowed by this rule; or (c) adding a clause or condition to the covered transaction with that person.
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing #21.027, we noted one instance where the County had a payment to a vendor of more than $25,000 and there was no evidence the County checked the EPLS, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the three contracts tested with covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2023.
Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred.
Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the EPLS, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods.
The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays.
In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation.
1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity.
2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed.
3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator.
4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle.
Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours.
The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023:
• Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period.
• Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period.
• One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not.
• Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed.
Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool.
The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.
45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments 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)(1) states the County Departments of Job and Family Services 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.
The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 50 days per review of the CR 502 reports in 2023. Therefore, the cash on hand exceeded the allowable number of days by 40 for the year.
The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.