Finding Text
2022-005 REPORTING
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).”
ETA-9130, Financial Report (OMB No. 1205-0461) – All ETA grantees are required to submit quarterly financial reports for each grant award they receive. Reports are required to be prepared using the specific format and instructions for the applicable program(s); in this case, Workforce Innovation and Opportunity Act instructions for the following: Statewide Adult; Workforce Statewide Youth; Statewide Dislocated Worker; Local Adult; Local Youth; and Local Dislocated Worker. Reports are due 45 days after the end of the reporting quarter. Financial data is required to be reported cumulatively from grant inception through the end of each reporting period.
WIOA Participant Individual Record Layout (PIRL) (OMB No. 1205-0526) - The report is used to report services, activities, and outcomes of service for all job seekers and veterans. The WIOA Adult, Dislocated Worker, and Youth Programs are responsible for reporting common WIOA performance indicators.
2 CFR 170 Appendix A, as it relates to reporting for the Federal Funding Accountability and Transparency Act, “unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.”
Condition: Upon inquiry of management, no supporting documentation could be provided that the ETA-9130, Financial Reports (OMB No. 1205-0461) and the WIOA Participant Individual Record Layout (OMB No. 1205-0526) performance reports required by the WIOA Cluster were prepared and submitted. Additionally, the entity made first tier subawards of greater than $30,000, but could not provide supporting documentation that the necessary reports were filed to satisfy the requirements of the Federal Funding Accountability and Transparency Act (FFATA).
Questioned Costs: Unknown
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 adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster and FFATA were submitted accurately and in a timely fashion.
Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award.
Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion.
Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.