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 area fiscal agents 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(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state.
Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings.
2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities.
3. For all submissions, 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.
4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications.
5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021
does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022.
6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree.
This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services.
The Consortium should develop and 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.