Auditors must be alert to improper payments, particularly when testing the following parts of section III. - A, “Activities Allowed or Unallowed;” B, “Allowable Costs/Cost Principles;” E, “Eligibility;” and, in some cases, N, “Special Tests and Provisions.”
2 CFR PART 200 Cost Principles for States, Governments and Indian Tribes Introduction , and establish principles and standards for determining allowable direct and indirect for Federal awards. This section is organized into the following areas of allowable costs: States and Local Government and Indian Tribe Costs (Direct and Indirect); State/Local Government Central Service Costs; and State Public Assistance Agency Costs. Cognizant Agency for Indirect , provides the guidelines to use when determining the Federal agency that will serve as the cognizant agency for indirect costs for States, local governments, and Indian tribes. References to the “cognizant agency for indirect costs” are not equivalent to the cognizant agency for audit responsibilities, which is defined in . In addition, the change from the term “cognizant agency” in OMB Circular A-87 to the term “cognizant agency for indirect costs” in 2 CFR part 200 was not intended to change the scope of cognizance for central service or public assistance cist allocation plans. For indirect cost and departmental indirect cost allocation plans, the cognizant agency is the Federal agency with the largest value of direct Federal awards (excluding pass-through awards) with a governmental unit or component, as appropriate. In general, unless different arrangements are agreed to by the concerned Federal agencies or described in 2 CFR part 200, Appendix V, paragraph F, the cognizant agency for central service cost allocation plans is the Federal agency with the largest dollar value of total Federal awards (including pass-through awards) with a governmental unit. Once designated as the cognizant agency for indirect costs, the Federal agency remains so for a period of 5 years. In addition, 2 CFR part 200, Appendix V, paragraph F, lists the cognizant agencies for certain specific types of plans and the cognizant agencies for indirect costs for certain types of governmental entities. For example, HHS is cognizant for all public assistance and State-wide cost allocation plans for all States (including the District of Columbia and Puerto Rico), State and local hospitals, libraries, and health districts and the Department of the Interior (DOI) is cognizant for all Indian tribal governments, territorial governments, and State and local park and recreational districts. (Source: 2016 OMB Supplement 3.2)
Audit Implications Summary Audit Implications (adequacy of the system and controls, and the effect on sample size, significant deficiencies / material weaknesses, material non-compliance and management letter comments) Results of Test of Controls: (including material weaknesses, significant deficiencies and management letter items) Assessment of Control Risk: Effect on the Nature, Timing, and Extent of Compliance (Substantive Test) including Sample Size: Results of Compliance (Substantive Tests: Questioned Actual __________ Projected __________
and ODJFS requirements including Chapter 7 () of the . Subgrantee agrees that amounts submitted as the basis for claims for reimbursement will not exceed the amount of actual cash expenditures for lawfully appropriate purposes under the terms of the subaward in question.” Public assistance (PA) financing and cash management is the rule for cash management. The rule can be found in chapter 7 of the . The requirements for cash management for the Department of Health and Human Services are contained in (b), as follows: Payment: For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. The Ohio Bureau of Workers’ Compensation of Directors has proposed a refund/rebate of county contributions to the Public Work-Relief Employees’ Fund for the time period January 1, 2005 through December 31, 2014. The original costs of these contributions were eligible expenditures under the Temporary Assistance for Needy Families or the Food Assistance Employment and Training (NKA SNAP E & T) programs and any refund/rebate must be returned to that program. On Friday 6/24/16, counties were notified that the BWC refunds/rebates being received must be reported as a receipt against current funding. The term “rebate” should have been used rather than “program income”. Although rebates are not technically defined as program income under TANF and FAET, the receipt of those rebates must still be credited against the Federal government as a cost reduction or cash refund and have the same limitations as the original grant money. In accordance with 45 CFR 75.305 (b)(5) entities must “…disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.” See also Section L (Reporting). Funding is based on expenditures but is not on a reimbursement basis.
Person(s) responsible for performing the control procedure (title): Description of evidence documenting the control was applied (i.e. sampling unit): Here are some questions that can help in documenting the control requirements Has the County/district JFS agency established written acquisition standards to ensure that all purchases of services, supplies, and equipment performed in accordance with applicable state / federal law and regulations? Has the County/district JFS agency established procedures to ensure that any sub-grantee entity was aware of the requirements contained in paragraph (A) of the OAC rule above and given written notice contained in any contract or grant agreement that all acquisitions made by the entity must conform to these requirements? The Guided Self-Assessment (GSA) if used or County/District JFS Policies should document controls for meeting compliance requirements. Auditors should review the information provided by the County/District JFS to gain an understanding of the procedures in place.