LOGAN, COUNTY OF

45 C.F.R. part 75 subpart D, section 75.305(b) states 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. Ohio Admin. Code § 5101:9-7-03(B) states that when a County Department of Job and Family Services (CDJFS) is funded on a reimbursement basis, program costs are paid by local funds before reimbursement is requested. When funds are drawn in advance, the CDJFS shall follow procedures to minimize the time elapsing between the transfer of funds from the state and local disbursement. Disbursements to a CDJFS administering federal programs shall cover allowable expenditures consistent with federal and state regulations. (1) Requests for cash draws may be submitted weekly and are processed by the Ohio department of job and family services (ODJFS) in six working days. In accordance with 45 C.F.R. part 75 subpart D, section 75.305, cash drawn in advance must be limited to the minimum amount needed for actual, immediate requirements. The CDJFS shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten day average for all federal funding. (2) Cash drawn shall be traceable to program expenditures sufficient to establish such funds have not been used in violation of the restrictions and prohibitions of applicable rules and regulations. The accounting systems of the CDJFS shall support internal controls necessary to insure federal grants and state funds remain separated on a grant, program, or project basis. Ohio Admin. Code § 5101:9-7-03(C) states (1) the county finance information system (CFIS) calculates the average number of days of cash on hand on an individual grant basis. This information is based on expenditures and cash draws reported in CFIS in accordance with rule 5101:9-7-29 of the Administrative Code and reflected in the CFIS over/under report. The average number of days of cash on hand is calculated as follows: (a) The cash on hand amount is calculated by deducting the reported expenditures over the lifetime of the funding source, up to the budgeted amount from the total amount of cash draws over the lifetime of the funding source; (b) The daily average expenditure amount is calculated by dividing the total reported expenditures by the number of calendar days the funding has been available; and (c) The average number of days of cash on hand is calculated by dividing the cash on hand from paragraph (C)(1)(a) of this rule by the average daily expenditures in paragraph (C)(1)(b) of this rule. (2) At the end of each quarter, the CDJFS shall review the CFIS cash on hand report to ensure compliance with paragraph (B)(1) of this rule. (a) If an event, beyond the reasonable control of the CDJFS, results in noncompliance with the cash management requirements, the CDJFS shall document the event. (b) If circumstances resulting in the noncompliance are caused by internal control deficiencies or operational processes, the CDJFS shall document the steps implemented to avoid a reoccurrence. (3) Continued non-compliance may result in ODJFS restricting the agency's draws to ensure the cash management practices of the CDJFS are in compliance with paragraph (B)(1) of this rule. The Logan County Department of Job and Family Services had 1 of the 4 quarters during fiscal year 2023 where the average cash on hand exceeded ten days for the Social Services Block Grant funding. Due to lack of internal controls over cash management, the County had over 167 days of cash on hand. The failure to comply with the cash management requirements per the federal C.F.R. and Ohio Administrative Code could result in the Ohio Department of Job and Family Services restricting the agency's draws to ensure the cash management practices are in compliance with the requirements or a loss of grant funding. The Logan County Department of Job and Family Services should review the policies and procedures in place for drawing down Federal grant monies to help ensure only cash needed for immediate use is requested. Furthermore, the drawdowns should be limited to cover transactions expected to be expended within ten days.

45 CFR § 1356.60(a)(1)(i) states "Federal financial participation (FFP) is available to title IV-E agencies under an approved title IV-E plan for allowable costs in expenditures for foster care maintenance payments as defined in section 475(4) of the Act, made in accordance with §§ 1356.20 through 1356.30, section 472 of the Act, and, for a Tribal title IV-E agency, section 479B of the Act..." Ohio Admin. Code § 5101:2-47-11 states: "(A) In order to be reimbursed for Title IV-E foster care maintenance (FCM) costs when a child is placed in a children’s residential center (CRC), group home, maternity home, residential parenting facility, or with a parent in a substance use disorder (SUD) residential facility as defined in rule 5101:2-1-01 of the Administrative Code a JFS 02911 "Title IV-E Single Cost Report" as described in rule 5101:2-47-26.1 of the Administrative Code is to be submitted to the Ohio department of job and family services annually. Agencies certified prior to October 1, 2020 have until October 1, 2024 to become compliant with the requirements related to meeting qualified residential treatment program (QRTP) standards. (B) If a JFS 02911 cost report has been approved for children placed in a CRC, group home, maternity home, residential parenting facility or SUD residential facility, two Title IV-E reimbursement ceiling amounts are calculated and rounded to the nearest dollar. (1)The FCM reimbursement ceiling amount is based on reported and allowable FCM costs. (2)The Title IV-E administration reimbursement ceiling amount is based on reported allowable Title IV-E administration costs. (C) Reimbursement to the Title IV-E agency for children placed in a CRC, group home, maternity home, residential parenting facility, or SUD residential facility is based on the lesser of: (1)The FCM reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for foster care maintenance. (2)The administration reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for administration." Furthermore, Ohio Admin. Code § 5101:2-47-11(G) states: "To receive reimbursement a Title IV-E agency processing their payments and seeking reimbursement from Ohio statewide automated child welfare information system (SACWIS) is to: (1)Record placement, service authorization and placement cost information for each child. (2)Generate a payment by creating a payment request and sending the payment information to the county auditor for payment. (3)Disburse payments through the county auditor at any point during a month. These payments will be reimbursed during the monthly reimbursement process conducted by ODJFS on the first business day of the following month. (4)Access reports to review all itemized reimbursements and assure the reimbursements are accurate." The Children's Services Department completed the required reporting within the SACWIS system; however, due to lack of controls over review of the system for accuracy, the August 2023 reimbursement was overpaid by 12 care days for one child. The SACWIS report was used for federal reimbursement to the Children's Services Department and thus resulted in $1,628 more in reimbursements than the department was entitled based on the provider invoices. Failure to properly report number of care days can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The Logan County Children's Services Department should implement policies and procedures to ensure the accuracy of data input within the SACWIS system.

2 CFR § 300.1 states the Department of Health and Human Services adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, and has codified the text, with HHS-specific amendments in 45 CFR part 75. Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the Department. 2 CFR § 200.403 which states, in part, that except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. The PRF and ARP Rural Distribution are administered by the Health Resources and Services Administration (HRSA) and support eligible health care providers in the battle against the COVID-19 pandemic. PRF provides relief funds to eligible providers of health care services and support for health care-related expenses or lost revenues attributable to coronavirus. ARP Rural Distribution addresses the disproportionate impact that COVID-19 has had on rural communities and rural health care providers. PRF and ARP Rural Distribution recipients must only use payments for eligible expenses. The recipient certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus and COVID-19, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus and COVID-19. 2022 OBM Compliance Supplement, Part 4, 93.498. Reporting Entities are required to maintain adequate documentation to substantiate that the PRF funds were used for health care-related expenses or lost revenues that are attributable to coronavirus and COVID-19. See PRB Reporting and Auditing FAQ, Health Resources & Services Administration, https://www.hrsa.gov/provider-relief/faq/reporting?categories=210&keywords=. For 2022, five out of the twenty-five employees (20%) tested did not have adequate documentation to support the hours worked and paid to the employees for COV+10 and/or COV+7 pay. Logan County Logan Acres Care Center Department was unable to locate all of the pickup bonus forms for five of the employees. These forms indicate the day, number of hours, and type of bonus the employee was approved for and received. Therefore, $998 of the $6,882 of employee wages tested did not have supporting documentation, resulting in a projected error of $39,233 and a questioned cost. Failure to maintain and provide adequate detailed financial records to support payments made could result in unallowable federal grant expenditures, reimbursements to the grantor, and/or additional questioned costs issued in future audits. Logan County Logan Acres Care Center Department should implement policies and procedures to identify, gather, and verify that adequate supporting documentation is received, reviewed, and maintained prior to issuing payments of grant funds.

2 CFR § 300.1 states the Department of Health and Human Services adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, and has codified the text, with HHS-specific amendments in 45 CFR part 75. Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the Department. 2 CFR § 200.329(a) states the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity. 45 CFR § 75.302(a) states each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Section (b) states, in part, the financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the HHS awarding agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 75.341 and 75.342. (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. (5) Comparison of expenditures with budget amounts for each Federal award. (6) Written procedures to implement the requirements of § 75.305. (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award. The COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution program is administered by the Health Resources and Services Administration (HRSA) and supports eligible health care providers in the battle against the COVID-19 pandemic by providing relief funds to eligible providers of health care services and support for health care-related expenses or lost revenues attributable to coronavirus. PRF recipients must only use payments for eligible expenses. 2022 OMB Compliance Supplement, Part 4, 93.498. Providers who accepted PRF and/or ARP payment(s) agreed to the Terms and Conditions of the program, which include a requirement to report on the use of the funds. See Reporting and Auditing, Health Resources & Services Administration, https://www.hrsa.gov/provider-relief/reporting-auditing. Entities receiving PRF funds are required to submit financial and other information in the Provider Relief Fund Reporting Portal. The PRF amounts to be reported on the County’s Schedule of Expenditures of Federal Awards (SEFA) are based on the PRF report. 2022 OMB Compliance Supplement. Reporting Entities are required to maintain adequate documentation to substantiate that the PRF funds were used for health care-related expenses or lost revenues that are attributable to coronavirus and COVID-19. See PRB Reporting and Auditing FAQ, Health Resources & Services Administration, https://www.hrsa.gov/provider-relief/faq/reporting?categories=210&keywords= . Logan County Logan Acres Care Center Department (the Center) completed and submitted its PRF report based solely on the amounts received; however, the Center did not submit and maintain detailed, complete financial records on the actual expenditures of the PRF funds. As a result, the exact expenditures associated with the grant were unidentifiable which was contrary to the requirements imposed on recipients of PRF funds. Logan County Logan Acres Care Center Department should implement procedures to verify grants are separately accounted for with respect to receipts and expenditures. Failure to maintain detailed financial records can result in unallowable federal grant expenditures and/or reimbursements to the grantor.

COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution- Reporting Finding Number: 2021-001 Assistance Listing Number and Title: AL #93.498 ? COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number / Year: 2021 Federal Agency: U.S. Department of Health and Human Services Compliance Requirement: Reporting Requirement Pass-Through Entity: N/A ? Direct Award Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR ? 300.1 states the Department of Health and Human Services adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, and has codified the text, with HHS-specific amendments in 45 CFR part 75. Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the Department. 2 CFR ? 200.329(a) states the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity. 45 CFR ? 75.302(a) states each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Section (b) states, in part, the financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the HHS awarding agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 75.341 and 75.342. (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. (5) Comparison of expenditures with budget amounts for each Federal award. (6) Written procedures to implement the requirements of ? 75.305. (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award. The Provider Relief Fund (PRF) is administered by the Health Resources and Services Administration (HRSA) and supports eligible health care providers in the battle against the COVID-19 pandemic by providing relief funds to eligible providers of health care services and support for health care-related expenses or lost revenues attributable to coronavirus. See 2021 OMB Compliance Supplement Addendum, Part 4, 93.498, Provider Relief Fund. PRF recipients must only use payments for eligible expenses. Providers who accepted PRF payment(s) agreed to the Terms and Conditions of the program, which include a requirement to report on the use of the funds. See Reporting and Auditing, Health Resources & Services Administration, https://www.hrsa.gov/provider-relief/reporting-auditing. Entities receiving PRF funds are required to submit financial and other information in the Provider Relief Fund Reporting Portal. 2021 OMB Compliance Supplement Addendum. The PRF amounts to be reported on the County?s Schedule of Expenditures of Federal Awards (SEFA) are based on the PRF report. Reporting Entities are required to maintain adequate documentation to substantiate that the PRF funds were used for health care-related expenses. See PRB Reporting and Auditing FAQ, Health Resources & Services Administration, https://www.hrsa.gov/provider-relief/faq/reporting?categories=210&keywords=. Logan Acres completed and submitted its PRF report based solely on the amounts received; however, Logan Acres did not submit and maintain detailed, complete financial records on the actual expenditures of the PRF funds. As a result, the exact expenditures associated with the grant were unidentifiable which was contrary to the requirements imposed on recipients of PRF funds. Logan Acres should establish and implement procedures to verify grants are separately accounted for with respect to receipts and expenditures. Failure to maintain detailed financial records can result in unallowable federal grant expenditures and/or reimbursements to the grantor.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION