Audit 391060

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 states that all OCJS projects are required to submit Quarterly Subgrant Reports (QSR), 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 on file for the Retention Incentive Grant for the first and second quarters of 2024. The only QSR was submitted in 2024 for the Retention Incentive grant covered the first 3 quarters of 2024 and it also reported corrections for the 2023 expenditures previously reported, created on October 28, 2024, and then modified on November 27, 2024. Additionally, the quarterly report was not filed for the 1st quarter and Quarterly reports were not submitted timely for Quarters 2 through 4 for the Operation Cleanup Grant. The Sheriff's Department reported both of these 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 differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted a variance between total reported expenditures compared to the county ledgers which resulted in an overstatement of $10,915 in reported expenditures. Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. The Court did not file quarterly reports for Quarters 1 or 2 in 2024 but instead filed only one final report for the period ending September 30, 2024 which was due by October 31, 2024, but filed on December 13, 2024. Failure to submit the required reports timely 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 based on actual information from underlying accounting 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. 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. Due to the delay of the grant start date, the first payment not made until 2023. During 2024, payments 7 through 10 were made lacking documentation of how the payment amounts were calculated. 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, and 2024 hourly rate for new employees in 2024. 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 that amounts paid to employees from Payment 7 through Payment 10 covering March through October 2024 were not adequately documented as we could not recalculate the bi-monthly payments totaling $13,476.52 in salaries and $2,072 in related benefits though we did note no employee received greater than 10% of their annual salary maximum. Lack of supporting documentation could result in noncompliance and/or questioned costs. 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. The grant was completed as of December 31, 2024.

Ohio Administrative Code § 5101:9-7-10 (B) states pursuant to 45 C.F.R. part 96, states are required to report services provided by the County Department of Job and Family Services (CDJFS), using federal, state or local social services funds. The CDJFS may provide services through compact services, direct services, purchased services or grant agreements as defined in rule 5101:2-25-02 of the Administrative Code. The purpose of the SSBG quarterly summary reporting system is to collect social services expenditure data by county each quarter in order to complete annual federal reporting as mandated in 42 U.S.C. 1397e. Further, Ohio Administrative Code § 5101:9-7-10 (C) states each CDJFS shall enter required service and expenditure data in the SSBG reporting system no later than the thirtieth day of the month following the last month of the quarter, e.g., October thirtieth for the July through September time period. The CDJFS shall submit a Title XX SSBG quarterly report even if SSBG direct services were not provided or purchased service expenditures were not made during the quarter. During testing of Quarter 2 for 2024, the expenditure data reported by the CDJFS for program code 738 was overstated $38,369 due to the CDJFS using the incorrect total from the CR454A report. This could result in delays in funding from CDJFS draw requests. Job and Family Services Fiscal Staff should review the data prepared for the quarterly reported prior to submission to ensure it does agree back to the underlying ledgers for quarterly expenditures.

Ohio Admin. Code 5101:9-7-20(E) outlines the procedures to be utilized for random moment sampling (RMS) time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services including those administered through the public children services agency. These procedures include an employee completing the required comments section, within WebRMS, with comments that demonstrate that the selected program and activity codes supporting the work performed by the assigned position at the time of the observation and ensuring adequate backup documentation is available to verify the activity being performed. The County Job and Family Services Agency did not ensure supporting source documentation was attached to the RMS observation for 3.3 percent of RMS time studies observations tested. The employees selected for these RMS observations failed to attach support when completing the observation. These time studies are used to allocate expenditures across the federal programs for the county agency and failure to maintain support for these activities could cause incorrect charges to federal programs. The County Job and Family Services Agency should revisit and implement internal control policies and procedures over its Random Moment Sample processes to ensure supporting source documentation is maintained or exists in order to be compliant with Federal laws and regulations.