Subrecipient/Vendor Compliance Franklin County DJFS December 6, 2011

FCDJFS Subrecipient Vendor Compliance Presentation 2 Agenda Introduction Introduction Subrecipients and VendorsSubrecipients and Vendors Subaward/Contract testingSubaward/Contract testing Internal Controls Internal Controls Expenditure Testing Expenditure Testing DSS update DSS update A-133/SEFA A-133/SEFA Payroll Payroll Equipment Equipment Pass-through/Subcontracts Pass-through/Subcontracts

FCDJFS Subrecipient Vendor Compliance Presentation 3 Internal Controls Criteria: Government Auditing Standards (Yellow Book) 7.16 Government Auditing Standards (Yellow Book) 7.16 OAC 5101: Subrecipient Annual Risk Assessment Review and Subrecipient Monitoring Process (H)(2)(e) OAC 5101: Subrecipient Annual Risk Assessment Review and Subrecipient Monitoring Process (H)(2)(e) OMB Circular A (b), 500 (c) OMB Circular A (b), 500 (c) Common Findings: Failure to have policies and procedures over approved budget items, i.e., travel reimbursement, credit cards, cell phone reimbursements Failure to have policies and procedures over approved budget items, i.e., travel reimbursement, credit cards, cell phone reimbursements Lack of segregation of duties in fiscal functions, or absence of policies over Agency functions, such as revenue and disbursements, cost allocations, purchasing, capital assets Lack of segregation of duties in fiscal functions, or absence of policies over Agency functions, such as revenue and disbursements, cost allocations, purchasing, capital assets

FCDJFS Subrecipient Vendor Compliance Presentation 4 Expenditure Testing Criteria: 2 CFR Part 230 (codification of OMB Circular A-122) Criteria: 2 CFR Part 230 (codification of OMB Circular A-122) 45 CFR Subpart Risk assessment statement 45 CFR Subpart Risk assessment statement Common Findings:  Inability to produce grant award - program specific financial statements to promote transparency  Incomplete or missing agreements/sub-contracts, and unsupported expenditures charged to grant (sales tax, other programs’ expenses)  Disproportionate allocation expense to our program  Lack of support for allowed expenditures (invoices, required signatures, transparent coding)  Unreasonable (not necessary for program administration, exceeding normal market values)

FCDJFS Subrecipient Vendor Compliance Presentation 5 DSS Update Budgets Budgets Cost to provide the service or run the programCost to provide the service or run the program Units of Service Units of Service Payment and Performance PointsPayment and Performance Points Invoices Invoices Request of payment for actual services provided and expensesRequest of payment for actual services provided and expenses Quarterly Expenditure Reports Quarterly Expenditure Reports Reports revenue and expensesReports revenue and expenses

FCDJFS Subrecipient Vendor Compliance Presentation 6 A-133 Schedule of Expenditures of Federal Awards Don Wells, CPA Don Wells, CPA Hemphill and Associates, Inc. Hemphill and Associates, Inc.

FCDJFS Subrecipient Vendor Compliance Presentation 7 Payroll testing Criteria: 2 CFR 230 (codification of OMB Circular A-122) Appendix B; 8. Compensation for personal services Common findings: Employees working on multiple grants not separately allocating time on time sheets Employees working on multiple grants not separately allocating time on time sheets No Leave slips present for employee’s accounting for vacation/sick/personal time No Leave slips present for employee’s accounting for vacation/sick/personal time Managers not signing employee timesheets Managers not signing employee timesheets Exempt staff not completing Personnel Activity Reports Exempt staff not completing Personnel Activity Reports

FCDJFS Subrecipient Vendor Compliance Presentation 8 Equipment Criteria: 45 CFR Procurement procedures OAC 5101: (B) (1) OAC 5101: (B) (1) Common findings: No subrecipient procurement plan No subrecipient procurement plan Failure to document procurement process Failure to document procurement process No allocation process to identify proper usage and identification of equipment costs charged to the FCDJFS grant No allocation process to identify proper usage and identification of equipment costs charged to the FCDJFS grant

FCDJFS Subrecipient Vendor Compliance Presentation 9 Pass-through and Subcontracting Subrecipients passing through funds assume monitoring responsibilities Subrecipients passing through funds assume monitoring responsibilities 2 nd Subawards not part of the original bid and acceptance must be procured through the Agency’s plan 2 nd Subawards not part of the original bid and acceptance must be procured through the Agency’s plan

FCDJFS Subrecipient Vendor Compliance Presentation 10 FCDJFS Web Site FAQ’s FAQ’s Power points of trainings Power points of trainings Self risk-assessment and internal control questionnaire Self risk-assessment and internal control questionnaire Subrecipient/vendor determination worksheet Subrecipient/vendor determination worksheet Other compliance related resources Other compliance related resources

FCDJFS Subrecipient Vendor Compliance Presentation 11 Questions??