Finding Text
2022-004 PERIOD OF PERFORMANCE
Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number
U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278
Criteria: 2 CFR 200.303 requires that a 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.”
Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions.
Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278
Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022.
Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment.
Effect: The Board could have had expenditures that were outside the proper period of performance of the grant.
Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment.
Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.