2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR 2900.4 gives regulatory effect to the Department of Labor for 2 CFR Subpart F § 200.510(b) which requires the auditee to prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the Consortium’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502.
At a minimum, the schedule must:
(1) List individual Federal programs by Federal agency.
(2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.
(3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL information is not available.
(4) Include the total amount provided to subrecipients from each Federal program.
(5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period.
(6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs.
The Consortium chose to report their Schedule of Federal Awards on a cash basis. The fiscal agent's accounting system operated on a full accrual basis and the federal schedule that was presented for audit was taken from the CFIS system for tracking federal expenditures for the Ohio Department of Job and Family Services. However, the Consortium was not able to provide support from the accounting system to reconcile the amounts reported on the Schedule to the accounting system.
Due to the lack of support for the federal schedule, we were unable to ensure that activity upon which we based our testing of the compliance for major federal programs was complete and therefore we could not obtain the necessary assurances to form an opinion over the major federal programs’ compliance. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agency in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Management should review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The Consortium should implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. This will help ensure the Consortium is in compliance with grant and loan requirements, the Schedule is complete and accurate, and major federal programs are accurately identified for audit.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, Ohio Admin. Code § 5101:9-7-29(D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions:
1. The fiscal agent did not maintain quarterly certification on file for the first and second quarter of calendar year 2023. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
2. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS.
3. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.
The Consortium should have established and maintained effective internal control over Federal award expenditures to provide reasonable assurance that the Consortium was managing Federal awards in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These controls should have included proper approval / authorization of all outgoing payments being made by the fiscal agent on behalf of the Consortium. It appeared the procedure that was supposed to be in place was that both the Director and the Comptroller were to sign off on all invoices prior to payments being made.
Due to the lack of controls over expenditures, during testing there was no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for ten out of the fifteen expenditures tested for the WIOA Cluster. There was also no indication on the invoice that the Director and Comptroller reviewed and approved the expenditures for eight out of the fourteen expenditures tested for the National Emergency Grant. Policies and procedures should be established and implemented to verify that controls over federal expenditures to timely prevent or detect noncompliance are in place and operating effectively. Failure to do so increases the likelihood of unallowable expenditures and material non-compliance with program requirements going undetected.
The Director and Comptroller should review and approve each invoice in order to determine that expenditures are in accordance with grant requirements and Federal laws and such approval should be documented on each invoice.