Finding Text
2022-007 ELIGIBILITY
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).”
Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance.
Condition: During our testing of WIOA participants, it was noted by management that the eligibility determination for Youth Activities is maintained and conducted by the Board’s subrecipient. According to management, there are no procedures performed at the Board to verify the eligibility of Youth Activities participants to ensure that all federal compliance requirements are being adhered to.
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 does not perform any procedures to ensure that the Youth Activities participants meet all the federal compliance requirements for participation in the program.
Effect: A Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements.
Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants.
Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.