Where do we get the money? How does it flow to the Regional Boards? How is it decided who gets how much? What is relevant to IT and Programs?
Federal Government ◦ US Department of Labor (USDOL) Workforce Investment Act (WIA) Wagner Peyser Reemployment Assistance Veteran Assistance ◦ Health and Human Services(HHS) Temporary Assistance for Needy Families (TANF)/Welfare Transition (WTP) State Level Opportunities and Earned Incentives Other Grant Opportunities and Local Partnerships Federal to State to Workforce Boards to Sub Recipients
Programs in the One Stop Centers managed by DEO Paid Staff. ◦ Wagner Peyser ◦ Veterans (DVOP and LVER) ◦ Extended Unemployment (EUC) Regional Boards Get Pass Thru Funds to Pay for support of DEO Staff in One Stops.
Provides Source of Funding Information Provides Period of Availability Provides Amount of Funding Spells out Financial Guidelines ◦ Admin and Program % Allowable Spells out Program Guidelines ◦ Purpose of Funds ◦ Training Parameters Spells out Reporting Guidelines
Programs Can’t Exist Without Funds Funding Depends on Well Run Programs Program Managers Make Decisions for Participants based on Guidelines IT Must Be Prepared for Special Needs in Tracking and Reporting based on NFA Guidelines
Federal Level OMB Circulars ◦ A-110Administrative Requirements ◦ A-122Cost Principles ◦ A-133Audit State Guidelines ◦ NFA Requirements ◦ Prior Approval ◦ State Law Food & Beverage Travel Accountability Act
Costs must be Reasonable and Necessary ◦ “Prudent Person Rule” Costs must be Allocable ◦ Clearly Benefit Program whether direct or indirectly charged Costs must be Allowable ◦ Sometimes Allowable with Conditions (i.e. Prior Approval)
It is OK to spend Federal Money on Bonuses for Employees? It is OK to Spend Federal Money on Travel to Mexico? It is OK to Spend Federal Money for Employee Morale? It is OK to Spend Federal Money on Developing IT Software For Sale? It is OK to Spend Federal Money on Goods or Services for Personal Use?
It is OK to spend Federal Money on Bonuses for Employees?
8.Compensation for personal services. J.Incentive compensation to employees based on cost reduction, or efficient performance, suggestion awards, safety awards, etc. are allowable to the extent that the overall compensation is determined to be reasonable and such costs are paid or accrued pursuant to an agreement entered into in good faith between the organization and the employees before the services are rendered, or pursuant to an established plan followed by the organization so consistently as to imply, in effect, an agreement to make such a payment.
It is OK to Spend Federal Money on Travel to Mexico?
51.Travel Costs e.Foreign travel. Direct charges for foreign travel costs are allowable only when the travel has received prior approval of the awarding agency. Each separate foreign trip must receive such approval. For purposes of this provision, “foreign travel” includes any travel outside Canada, Mexico, the United States, and any United States territories and possessions.
http://www.doleta.gov/regs/statutes/wialaw.pdf http://www.doleta.gov/regs/statutes/wialaw.pdf (e) LIMITATION ON USE OF FUNDS.—No funds available under this title shall be used for employment generating activities, economic development activities, investment in revolving loan funds, capitalization of businesses, investment in contract bidding resource centers, and similar activities that are not directly related to training for eligible individuals under this title. No funds available under subtitle B shall be used for foreign travel.
It is OK to Spend Federal Money for Employee Morale?
13. Employee morale, health, and welfare costs. a.The costs of employee information publications, health or first-aid clinics and/or infirmaries, recreational activities, employee counseling services, and any other expenses incurred in accordance with the organization’s established practice or custom for the improvement of working conditions, employer- employee relations, employee morale, and employee performance are allowable.
It is OK to Spend Federal Money on Developing IT Software For Sale?
Raises more questions ◦ Developing Software for Local Board Use? ◦ Developing Software for Other Regions? ◦ Developing Software for Public Sale? ◦ Developing Software for Sale to Other Regions? In this case more Research should be done prior to any action.
It is OK to Spend Federal Money on Goods or Services for Personal Use?
19. Goods or services for personal use Costs of goods or services for personal use of the organization’s employees are unallowable regardless of whether the cost is reported as taxable income to the employees.
It is OK to Spend Money Passed through the State on Airline Baggage Fees? It is OK to Spend Money Passed through the State on Contracts with Board Members? It is OK to Spend Money Passed through the State on Training for Participants not Registered in EFM? It is OK to Spend Money Passed through the State on Food for Board Meetings? It is OK to Spend Money Passed through the State on Memberships to Chambers of Commerce?
It is OK to Spend Money Passed through the State on Airline Baggage Fees?
Non Accountability Act Item Not in State Guidance Local Policy Dictates.
It is OK to Spend Money Passed through the State on Contracts with Board Members?
Florida Statutes 445.007 (11) Contracts with Board Members must be approved by a two-thirds vote of the board when a quorum has been established. Contracts over $25,000 must have prior approval of WFI. Contracts under $25,000 must be reported to DEO & WFI, but do not need prior approval.
It is OK to Spend Money Passed through the State on Training for Participants not Registered in EFM?
Non Accountability Act Item WIA participants must be registered in EFM. Welfare Transition participants in training are not registered in EFM, but reported through OSST. Participant training using discretionary funds may or may not be registered in EFM.
It is OK to Spend Money Passed through the State on Food for Board Meetings?
Florida Statutes 445.007 (10) State and federal funds provided to the regional workforce boards may not be used directly or indirectly to pay for meals, food, or beverages for board members, staff, or employees of regional workforce boards, Workforce Florida, Inc., or the Agency for Workforce Innovation except as expressly authorized by state law. Preapproved, reasonable, and necessary per diem allowances and travel expenses may be reimbursed. Such reimbursement shall be at the standard travel reimbursement rates established in s. 112.061 and shall be in compliance with all applicable federal and state requirements.112.061
It is OK to Spend Money Passed through the State on Memberships to Chambers of Commerce?
Non Accountability Act Item OMB A-122 30. Memberships, Subscriptions, and professional activities a. Costs of the organization’s membership in business, technical, and professional organizations are allowable.
Local Policies and Procedures can be more strict with guidelines on how the money is spent. ◦ Procurement Policy ◦ Contracting ◦ Documentation Necessary ◦ Cost Allocation Plans Followed
Disallowed Costs May Financially Disable A Region’s Ability to Provide Services Public Perception for Misuse of Funds Can Severely Damage the Workforce System at all Levels Knowing the Rules Up Front Will Save Time in Correcting Errors Later
Accounting Software Integrated Systems for Money Spent on Participants Integrated Systems for Payroll
Must Have the Ability to Track Revenue and Expense by Funding Source Must be Current Must be Fast Must be Backed Up Must be Secure Can be Integrated with Multiple Software Programs Can be Hosted “In the Clouds”
Can be used to Track Expenditures by Participant ◦ Gazelle Software Tracks ITA Vouchers Tracks Support Services Tracks Debit Cards for Participants Transfers Automatically to Accounting Software Can be used for Payroll and Purchase Orders ◦ Microix Software Process Payroll and Purchase Orders Transfers Automatically to Accounting Software
Integrated Systems can alert Program Managers when Participant Budgets are Overspent or Underutilized. Integrated Systems support better Communication between Program and Finance. Integrated Systems can save time allowing Case Managers to serve more Participants. Program Case Managers and Program Managers need to understand how integrated systems with Finance differ from EFM.
IT Support for Financial Systems is extremely important in order to pay the bills on time. IT Security for Financial Systems is extremely important since that is a source of confidential information for both participants and personnel. IT needs clear understanding of how Program and Finance can utilize Integrated Systems
Financial Statements ◦ Balance Sheet (Snapshot in Time) ◦ Income Statement (Income and Expense) OSMIS Reports for DEO ◦ Must Reconcile to Financial Statement ◦ Must Report All Required Categories and Sub Categories Regional Board Requests ◦ Line Item Budget V Actual Analysis
Assets ◦ Cash$100,000 ◦ Receivables$ 20,000 $120,000 Liabilities ◦ Short Term Liabilities $ 30,000 ◦ Long Term Liabilities $ 10,000 $ 40,000 Equity $ 80,000 $120,000 Total Assets = Total Liabilities + Equity
So you have a basic understanding of the size and health of your organization. So you can see by funding source and by line item the areas of expenditures that you may be responsible for. So your eyes do not glaze over when you are provided the Financial Reports for your Region.
Local and State Board of Directors Monitors from DEO and/or USDOL ◦ Fiscal Monitors ◦ Program Monitors Independent Auditors
Monitors (Fiscal and Program) ◦ Review Information on a regular basis to see if Regions are measuring up to the guidelines set forth at the Federal and State Level. ◦ Review Policies, Procedures, and Plans to see if Regions are doing what they say they are. ◦ Look for potential areas of risk ◦ Suggest areas for improvement ◦ Review Audited Financial Statements
Independent Auditors (Fiscal Only) ◦ Provide an opinion on whether the financial statements are presented fairly in all material aspects, in accordance with applicable financial framework in order to enhance the degree of confidence that intended users can place in the financial statements. ◦ Audits are conducted in accordance with Generally Accepted Auditing Standards by Certified Public Accountants. ◦ Review Monitoring Reports
FMA is the State Bureau of Financial Monitoring and Accountability Fiscal Monitoring is now an on-going process provided in house by DEO Monitoring Teams throughout the State What is a Monitoring Tool?
IT Practices are Monitored along with Fiscal Monitoring. IT needs to explain to Monitors and Auditors their back-up plans for continuing operations of the organization in the event of a disaster (COOP). Program Files are reviewed as part of the Monitoring and Auditing process and need to be in order. Everyone needs to be prepared to explain and back up their answers to Monitors and Auditors. Continuation of Funding could be in Jeopardy
Required by State Law to be Approved by Local Authority and Provided to DEO. Forces an Organization to analyze and prioritize. Provides Expenditure Limits by Line Item by Funding Source. Provides a basis for expenditure comparisons all during the year.
Best Practice—Management Team to meet monthly to review spending status. Review Training Expenditures to meet ITA spending requirements. Review Salaries and Benefits to allow for evaluations, increase in staff or decrease in staff.
Review Sub Recipient expenditures to see if on target. Project what portion of budget will be over or under at the end of each fiscal year. Maximize efficiency. Leave no money on the table!
A process designed to provide “Reasonable Assurance” regarding the achievement of objectives in these categories: ◦ Effectiveness and Efficiency of Operations ◦ Reliability of Financial Reporting ◦ Compliance with Applicable Laws and Regulations
OMB Circular A-110 (Administrative) requires that Non Federal Entities (that would be us) establish and maintain effective control over and accountability for all Funds, Property and Other Assets. Help ensure that the Direction, Policies, Procedures, and Practices are in place and functioning.
Control Environment Risk Assessment Control Activities Information and Communication Monitoring
ICQ = Internal Control Questionnaire Management Teams complete the Self Assessment and turn into the Bureau of Financial Management & Accountability at DEO. Monitoring Teams use as guide to test and assess whether or not Boards are doing what they say they are doing in the area of Internal Controls.
A Best Practice Tool to identify “Who Does What to Create an Environment where NOT One Individual is Responsible for Management or Control of the Organization’s Assets
Cash as an example: ◦ Who Draws from State ◦ Who Receives? ◦ Who Records? ◦ Who Opens the Bank Statement? ◦ Who Reconciles the Bank Statement? ◦ Who Reconciles the Cash Account in the Financials to the Reconciled Bank Statement?
Regional Boards Should: ◦ Analyze Risks as a Basis for Determining How Risk Should be Managed. ◦ Consider the Potential for Fraud in Assessing Risks. ◦ Identify Changes that could have Significant Impact.
OMBOffice of Management and Budget ICQInternal Control Questionnaire NFANotice of Funds Available OSMISOne Stop Management System NEGNational Emergency Grant USDOLUnited States Department of Labor HHSHealth and Human Services FMAFinancial Monitoring and Accountability ITAIndividual Training Account COOPContinuity of Operations Plan
FOGFinance Officers Group CFDA #Catalog of Federal Domestic Assistance Number PYProgram Year FYFiscal Year GAAPGenerally Accepted Accounting Practices d/b/aDoing Business As APAccounts Payable ARAccounts Receivable JEJournal Entry ETAEmployment and Training Administration
RFPRequest for Proposal ITNInvitation to Negotiate OIGOffice of the Inspector General ROIReturn on Investment FTEFull Time Equivalent DORDepartment of Revenue FEINFederal Employer Identification Number (Tax ID) AICPAAmerican Institute of Certified Public Accountants GLGeneral Ledger GAOGovernment Accountability Office