Finding Text
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.