31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.
31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds.
The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested.
The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023.
The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers.
Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding.
The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.
2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect.
The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024.
The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained.
Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations.
Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits.
The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.