Audit 413056

The grant agreement between the Ohio Department of Job and Family Services (ODJFS) and Franklin County Department of Job and Family Services (the County) for the Refugee Entrant Assistance (REA) program states the County will submit one copy of a detailed invoice on a monthly basis via email to the ODJFS Agreement Manager by the 25th of the month. Further, the Subgrant Agreements between the County and Community Refugee & Immigration Services (CRIS) and Jewish Family Services (the Subrecipients) for the REA program state the Subrecipient shall bill monthly, and the invoice shall be received by the County no later than fifteen (15) calendar days following the month of service. If the 15th falls on a holiday or weekend, the invoice is due the following business day. The County did not have adequate internal controls in place to ensure invoices were submitted by the Subrecipients to the County, and by the County to ODJFS, in accordance with the grant agreements. Two out of seven (29%) of the subrecipient invoices tested and two out of three (67%) of the County invoices tested were not submitted to the proper authority in a timely manner, as shown below: Subrecipient Invoices: Subrecipient Service Month Submission Date CRIS January 02/19/2025 Jewish Family Services August 09/23/2025 County Invoices: Service Month Submission Date April 06/23/2025 July 10/22/2025 The County is responsible for ensuring the Federal requirements of the Federal grant award are met. Failure to submit invoices timely may result in reimbursement requests being denied and in noncompliance with Federal payment requirements. The County should implement internal controls that help ensure invoices are submitted timely, as required by the grant agreements, and to ensure Federal requirements are met. Officials’ Response: Refer to corrective action plan.

For programs audited on or after October 1, 2025 2 CFR § 300.106 gives regulatory effect to the Department of Health and Human Services for 2 CFR § 200.332(g), which states a pass-through entity must verify that every subrecipient is audited as required by subpart F of this part. Subpart F details the Single Audit requirements for non-Federal entities expending more than $1,000,000 in Federal awards in a fiscal year. For programs audited on or before September 30, 2025 45 CFR § 75.352(f) states a pass-through entity must verify that every subrecipient is audited as required by subpart F of this part. Subpart F details the Single Audit requirements for non-Federal entities expending more than $1,000,000 in Federal awards in a fiscal year. The Subgrant Agreements between the Ohio Department of Job and Family Services (ODJFS) and Franklin County Department of Job and Family Services (the County) (Subgrantee) and between the County and US Together (Subrecipient) for the Refugee Support Services (RSS) program, state the Subgrantee will ensure that subrecipients expending $1,000,000 or more in Federal awards during the subrecipient’s fiscal year have met the audit requirements of this Agreement for that fiscal year. The County did not have the proper internal controls in place to help ensure that all subrecipients of the AL # 93.566 program were audited as required by subpart F. We noted 1 out of 4 (25%) of the AL # 93.566 program subrecipients did not receive a Single Audit for fiscal year 2025 and have not had a Single Audit since 2018. Failure to ensure that program subrecipients receive Single Audits could result in subrecipients’ noncompliance, questioned costs going undetected, and additional risks for the County as the passthrough entity. The County should establish internal control procedures to help ensure all subrecipients are audited according to subpart F, and that management review the subrecipients' Single Audit reports for findings or results that could impact the operations and decision-making of the County. Officials’ Response: Refer to corrective action plan.

The Revenue Support Services (RSS) grant agreement between the Ohio Department of Job and Family Services (ODJFS) and the Franklin County Department of Job and Family Services (the County) states in Article I, Subgrant Activities, that copies of the signed Acknowledgement of Rights and Responsibilities form must be maintained in participant profiles. The form must be acknowledged by the participant, the caseworker, and the interpreter when the form was not translated into the participant's primary language. Additionally, Article I requires the participant's self-sufficiency contract to be reviewed every six months and a follow-up assessment of the participant's progress toward established goals to be completed and documented. Furthermore, Appendix B of the Franklin County Department of Job and Family Services Purchase of Service Subaward Agreements (the subaward agreement) require employment counseling, employer collaboration, and employment tracking every six and twelve months. For programs audited on or after October 1, 2025 2 CFR § 300.106 gives regulatory effect to the Department of Health and Human Services for 2 CFR § 200.332(e), which states, in part, that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals and objectives are achieved. For programs audited on or before September 30, 2025 45 CFR § 75.352(d) states in part that 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. The County did not have adequate internal controls in place to ensure its subrecipients complied with the requirements of the RSS grant and subaward agreements and did not adequately monitor subrecipient compliance with these requirements. During our testing of 60 participant packets maintained by the County's subrecipients, we noted the following: • Nine (9) of 60 (15%) participant packets tested did not contain the participant's signature on the RSS Acknowledgement of Rights and Responsibilities form, as required by Article I of the RSS grant agreement. • Five (5) of 60 (8%) participant packets tested did not contain documentation that the required six-month and/or twelve-month follow-up assessments were completed after the participant's initial enrollment, as required by Article I of the RSS grant agreement and Appendix B of the subaward agreement. The County's failure to adequately monitor its subrecipients contributed to these instances of noncompliance not being identified and corrected in a timely manner. Failure to obtain and maintain required participant acknowledgements increase the risk that participants may not fully understand program requirements, their rights and responsibilities, or the consequences of noncompliance. Failure to complete and document required follow-up assessments increases the risk that participant progress toward established self-sufficiency goals is not adequately monitored. Additionally, inadequate subrecipient monitoring increases the risk that noncompliance with federal requirements and the terms and conditions of the RSS grant agreement may occur and remain undetected, which could result in questioned costs, repayment of grant funds, or other corrective action by the grantor. We recommend the County establish and implement procedures to adequately monitor its RSS subrecipients for compliance with applicable federal requirements and the terms and conditions of the RSS grant and subaward agreements. Monitoring procedures should include a review of participant files to ensure required acknowledgements are obtained and maintained and required follow-up assessments are completed and documented. The County should document the monitoring performed, communicate identified deficiencies to its subrecipients, and follow up to ensure corrective action is taken in a timely manner. Officials’ Response: Refer to corrective action plan.