Disbursements Criteria – Internal controls over safeguarding assets constitute a process, effected by an entity’s governing body, management and other personnel designated to provide reasonable assurance regarding prevention or timely detection of unauthorized transactions and safeguarding assets from error or misappropriation. Such processes include establishing policies addressing proper authorization of the disbursement. Disbursements should be approved by the Local Workforce Development Board prior to funds being disbursed. Condition – All thirty-six transactions tested were approved by the Executive Director, the Finance Committee Chairperson, or the Board Treasurer, but were not approved by the Local Workforce Development Board prior to funds being disbursed. Cause – The Local Workforce Development Area's board allowed for disbursements to be approved only by the Executive Director, Finance Committee Chairperson, or Board Treasurer, but could not provide documentation this process was approved by the board. Effect – Lack of following policies and procedures requiring approval could result in unauthorized transactions and the opportunity for misappropriation. Recommendation – The Local Workforce Development Area should adhere to written policies and procedures requiring prior independent approval of all disbursements before payment. Response and Corrective Action Planned – The ECIWDB acknowledges this deficiency and commits to taking the following corrective action: Documented establishment of a procedure that will allow for the Executive Director to approve payments in real time, with subsequent affirmation by the Finance Committee at their monthly meetings. This procedural change shall be implemented on or about November 1, 2025. Conclusion – Response accepted.
Eligibility Criteria – Documentation is required to be kept showing that orientation has been completed by applicants prior to the applicants receiving aid through the program. Condition – No documentation was kept to determine if orientation has been completed for 25 of 25 individuals tested. Cause – The Local Workforce Development Area has not established policies and procedures to ensure orientation was being documented to ensure it was performed. Effect – No documentation was available to determine orientation was completed for applicants tested. Recommendation – The Local Workforce Development Agency should establish policies and procedures to ensure documentation is retained for orientation to show it has been completed. Response and Corrective Action Planned – The ECIWDB acknowledges the merit of this recommendation and commits to taking the following action: The establishment of a procedure that incorporates the utilization of an ‘Orientation Acknowledgement Form’ to demonstrate completion by each individual participant. This procedural change shall be implemented on or about November 1, 2025. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of those data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes, in part, identification of whether the award is research and development (R&D), the indirect cost rate for the federal award (including if the de minimis rate is charged) per Part 200.414, the subrecipient unique identifier (UEI #), the federal award date of award to the recipient by the Federal agency, the Assistance Listing number and Title. Additionally, the Workforce Innovation and Opportunity Act (WIOA) Section 102(b) defines priority of service for veterans and eligible spouses and WIOA Section 502(a) states that no WIOA funds can be spent unless the subrecipient agrees to comply with the Buy American Act. Condition – For subawards the Local Workforce Development Area did not include identification of whether the award is R&D, the indirect cost rate for the federal award (including if the de minimis rate is charged) per part 200.414, the subrecipient UEI, the federal award date of award to the recipient by the Federal agency, the Assistance Listing number and Title. Additionally, the Final Decision letter and Initial monitoring report were not signed. Cause – The Local Workforce Development Area has not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients was not included due to the lack of policies and procedures. Recommendation – The Local Workforce Development Area should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332 and WIOA. Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provided to Iowa Workforce Development (IWD) and AOS Senior Auditor Tristan Swiggum. Conclusion – Response accepted.
Subrecipient Monitoring Criteria – The Uniform Guidance, Part 200.332 states in part, “All pass-through entities must: evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.” The Uniform Guidance, Part 200.332 also states, “All pass-through entities must: monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward and issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Part 200.521.” The Uniform Guidance, Part 200.332 also states, “All pass-through entities must: Verify that every subrecipient is audited as required by Subpart F when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Part 200.501.” and that “All pass-through entities must: consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records.” Condition – The Local Workforce Development Area did not evaluate the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the Local Workforce Development Area did not evidence the review of the subrecipient’s audit report or have procedures in place to track and monitor the status of audit findings that require follow-up. Cause – The Local Workforce Development Area has not established policies and procedures to ensure compliance with Uniform Guidance, Part 200.332. Effect – The Local Workforce Development Area did not evaluate the subrecipient’s risk of noncompliance or monitor the status of subrecipient’s audit reports and audit finding due to a lack of policies and procedures. Recommendation – The Local Workforce Development Area should establish policies and procedures to ensure compliance with the Uniform Guidance, Part 200.332. Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both documents have since been provided to Iowa Workforce Development to demonstrate compliance with WIOA and Uniform Guidance, Part 200.332. Conclusion – Response accepted.