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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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.
Criteria: • §200.303 Internal controls establishes that “The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards, (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards., (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. • • 2 CFR §200.332 Requirements for pass-through entities establishes 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. • • Pass-through entity monitoring of the subrecipient must include (1) Reviewing financial and performance reports required by the pass-through entity; (2) 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; (3) 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 § 200.521; and (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings”. Condition: The Chapter 11 Subrecipients Management and Monitoring Manual, subrecipients with risk assessment profile classified as High-High Risk (HH), require an annual site visit. However, during the year ended June 30, 2020, from six (6) subrecipients classified as HH, two (2) were not visited during the period. The subrecipients not visited were the following: Cause: Lack of implementation of work plan that includes monitoring process for at least major subrecipients before year end, in order to avoid noncompliance on subrecipients’ procedures. Effects: • • Noncompliance may be performed by subrecipients without timely evaluation to remediate possible questioned costs, which may result in delay receipt of funds through remediation be implemented. • • Incomplete monitoring process can prevent COR3 from timely detection of a material noncompliance from subrecipients. Questioned Costs: None. Identification as a repeat finding: Finding is a repeat of a finding in the immediately prior year and was identified as finding number 2019-07. Recommendation: • • We recommend management to implement a work plan for monitoring subrecipients to ascertain that major subrecipients be monitored during the year, or at reaching to determine threshold on used federal funds used in order to timely react to and avoid possible non-compliances. • • In addition, we recommended management to ascertain that all procedures related to the monitoring process be implemented.
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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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.
Criteria: • §200.303 Internal controls establishes that “The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards, (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards., (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. • • 2 CFR §200.332 Requirements for pass-through entities establishes 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. • • Pass-through entity monitoring of the subrecipient must include (1) Reviewing financial and performance reports required by the pass-through entity; (2) 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; (3) 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 § 200.521; and (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings”. Condition: The Chapter 11 Subrecipients Management and Monitoring Manual, subrecipients with risk assessment profile classified as High-High Risk (HH), require an annual site visit. However, during the year ended June 30, 2020, from six (6) subrecipients classified as HH, two (2) were not visited during the period. The subrecipients not visited were the following: Cause: Lack of implementation of work plan that includes monitoring process for at least major subrecipients before year end, in order to avoid noncompliance on subrecipients’ procedures. Effects: • • Noncompliance may be performed by subrecipients without timely evaluation to remediate possible questioned costs, which may result in delay receipt of funds through remediation be implemented. • • Incomplete monitoring process can prevent COR3 from timely detection of a material noncompliance from subrecipients. Questioned Costs: None. Identification as a repeat finding: Finding is a repeat of a finding in the immediately prior year and was identified as finding number 2019-07. Recommendation: • • We recommend management to implement a work plan for monitoring subrecipients to ascertain that major subrecipients be monitored during the year, or at reaching to determine threshold on used federal funds used in order to timely react to and avoid possible non-compliances. • • In addition, we recommended management to ascertain that all procedures related to the monitoring process be implemented.
Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Criteria: In accordance with CFR part 200.332, a pass-through entity’s monitoring responsibilities include verification that every subrecipient is audited when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold set forth in §200.501 Audit requirements. In addition, to equally distribute subawards, CHCC should issue public publication notices for interested nonprofit organizations to apply. Condition: Of five subrecipients tested, aggregating $160,000 of a total population of $468,864, the following deficiencies were noted: 1. For five (or 100%), documentation of the monitoring procedures performed to determine whether any of the subrecipients expended $750,000 or more in federal funds and whether those that expended $750,000 or more were audited, were not provided. Total FY2019 expenditures under the subrecipient agreements were $353,864, which is a questioned costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: Test of fourteen nonpayroll expenditures pertaining to subrecipient transactions, aggregating $438,864 of a total population of $468,864, the following deficiencies were noted: 2. For fourteen (or 100%), public publication notices of subaward opportunities were not provided. Total FY2019 expenditures under the subrecipient agreements for Document Numbers 1436077, 1436266, 1456803 and 1446815 amounted to $115,000, which are for the same subrecipients, are questioned. No questioned costs are presented for the other Document Numbers as amounts are questioned at Condition 1, for which are for the same subrecipients. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: 3. For one (or 7%), supporting documents were not provided. No questioned costs is presented as the amount questioned at Condition 2 for Document Number 1436077 is for the same subrecipient. Cause: CHCC did not enforce recordkeeping and monitoring controls over applicable subrecipient monitoring requirements. Effect: CHCC is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $468,864 result. Identification as a Repeat Finding: Finding No. 2018-019. Recommendation: CHCC should establish and enforce required monitoring procedures and establish a recordkeeping system whereby underlying support for each transaction is processed timely and filed accordingly for easy retrieval to substantiate costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 1 to 3. Auditor Response: Condition 1 - Invoices, receipts and progress reports from prior disbursements were not provided. Condition 2 - Public publication notices of subaward opportunities were not provided. Condition 3 - We were not made aware that the transaction was voided and the corresponding reversal journal entry was also not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.
Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Criteria: In accordance with CFR part 200.332, a pass-through entity’s monitoring responsibilities include verification that every subrecipient is audited when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold set forth in §200.501 Audit requirements. In addition, to equally distribute subawards, CHCC should issue public publication notices for interested nonprofit organizations to apply. Condition: Of five subrecipients tested, aggregating $160,000 of a total population of $468,864, the following deficiencies were noted: 1. For five (or 100%), documentation of the monitoring procedures performed to determine whether any of the subrecipients expended $750,000 or more in federal funds and whether those that expended $750,000 or more were audited, were not provided. Total FY2019 expenditures under the subrecipient agreements were $353,864, which is a questioned costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: Test of fourteen nonpayroll expenditures pertaining to subrecipient transactions, aggregating $438,864 of a total population of $468,864, the following deficiencies were noted: 2. For fourteen (or 100%), public publication notices of subaward opportunities were not provided. Total FY2019 expenditures under the subrecipient agreements for Document Numbers 1436077, 1436266, 1456803 and 1446815 amounted to $115,000, which are for the same subrecipients, are questioned. No questioned costs are presented for the other Document Numbers as amounts are questioned at Condition 1, for which are for the same subrecipients. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Condition, continued: 3. For one (or 7%), supporting documents were not provided. No questioned costs is presented as the amount questioned at Condition 2 for Document Number 1436077 is for the same subrecipient. Cause: CHCC did not enforce recordkeeping and monitoring controls over applicable subrecipient monitoring requirements. Effect: CHCC is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $468,864 result. Identification as a Repeat Finding: Finding No. 2018-019. Recommendation: CHCC should establish and enforce required monitoring procedures and establish a recordkeeping system whereby underlying support for each transaction is processed timely and filed accordingly for easy retrieval to substantiate costs. Finding No.: 2019-012, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding described in Conditions 1 to 3. Auditor Response: Condition 1 - Invoices, receipts and progress reports from prior disbursements were not provided. Condition 2 - Public publication notices of subaward opportunities were not provided. Condition 3 - We were not made aware that the transaction was voided and the corresponding reversal journal entry was also not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.
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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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 areas 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 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, 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. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, 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 Ohio Department of Job and Family Services. The Consortium should 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.