TANF Summer Youth Camp Subaward Compliance Overview Cliff Marsh FCDJFS Department Auditor March 7, 2012

Compliance Environment FCDJFS monitored by ODJFS and Auditor of State Findings for recovery by FCDJFS

Areas of Review Internal Controls Payroll Allowability Allocability Subcontracts Subaward Terms

Internal Controls Policies and procedures should exist to support allowable expenditures

Payroll Direct Staff must have adequate documentation of their time and effort attested to an official with knowledge of their work Indirect Staff (admin) must have a breakout of their time spent across shared programs

Allowability Documentation of expenditures Expenditures supported by subaward Reasonableness test

Allocability Direct and Indirect Expenses Must be allowable Must have a reasonable, documented basis Must represent FCDJFS’ “fair share”

Allocability Direct Expenses Included in the budget Provide direct services for program participants Supported by a Cost Allocation Plan “Fair Share” for FCDJFS

Allocability Indirect Expenses Supported by Indirect Cost Plan Properly allocated to FCDJFS grant based on period of allowability and benefit to subaward participants

Subcontracts Leases and Services Do not treat subcontractors as employees Sound contracting language

Subaward Terms and Conditions Budget Clarification of Terms Program Narratives Prior audits and other reviews

Questions?  Related Links FCDJFS Subrecipient and Vendor Compliance Tools