FLORIDA CROWN WORKFORCE BOARD, INC

2024-008 WIOA Cluster Eligibility Support Criteria: According to the Compliance Supplement, 2 CFR PART 200, APPENDIX XI, published by the Office of Management and Budget (OMB) for the Workforce Innovation and Opportunity Act (WIOA) Cluster, for eligibility for individuals, the Local Workforce Development Board (LWDB) must perform its own assessment of the eligibility requirements of participants for WIOA cluster programs. Condition: In the current year, of the six participants tested for eligibility assessments by the LWDB, the LWDB was unable to provide the applicable eligibility forms and documentation of eligibility determinations. Cause: Due to the transfer of operations beginning on July 1, 2024, to a new LWDB, turnover within the LWDB, and movement to a new office, the LWDB was not able to locate the applicable eligibility forms and documentation of eligibility determinations. Effect: No supporting documentation for four participants was available, and therefore, we were unable to ascertain if the LWDB completed the required eligibility forms and if the required documentation and assessment of participant eligibility was completed. Recommendation: We recommend that the Organization ensure proper documentation as required by WIOA is retained and accessible to document compliance with grant requirements. Response: Management concurs with the finding and recommendation. The missing supporting documentation for the four participants was a result of the certain documents not being turned over from LWDB 7 to LWDB 9 during the transition period. The new consolidated entity, LWDB 26, has processes in place to track and store all required eligibility forms, utilizing a secure document management system. Additionally, LWDB 26 has internal and external Quality Assurance reviews, including annual Florida Commerce monitoring, to assure eligibility requirements are met, documented and stored for each participant.

2024-009 WIOA Cluster Matching Noncompliance Criteria: According to the Compliance Supplement, 2 CFR PART 200, APPENDIX XI, published by the Office of Management and Budget (OMB) for the WIOA Cluster, Local Areas: "(1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within State allocations." Condition: In the current year, the Organization failed to expend no more than 10% in administrative costs in the WIOA cluster, expending 13.31%. Cause: The Organization did not properly monitor administrative expenses for the WIOA Cluster to ensure that the overall percentage allocated to administrative expenses was no more than 10%. Effect: The Organization was not in compliance with the Matching requirements under the WIOA cluster. Recommendation: We recommend that the Organization ensure that expenses - and specifically administrative expenses - be properly tracked to ensure compliance with WIOA cluster grant requirements. Response: Management concurs with the finding and recommendation. Due to the termination of awards effective June 28, 2024, FL Crown did not have the ability to reclassify administrative costs to subsequent program year awards. The new consolidated entity, LWDB 26, monitors the 10% cap with each monthly cash draw and benefits from having an interlocal agreement with Alachua County to provide administrative support services at a capped rate of 3.5% of formula awards.

2024-010 WIOA Cluster Activities Allowed/Allowable Costs Support Criteria: According to the Compliance Supplement, 2 CFR PART 200, APPENDIX XI, published by the Office of Management and Budget (OMB) for the WIOA Cluster, for activities allowed/unallowed and allowable costs, expenses must only be spent on those items and activities which are noted to be allowable by the WIOA cluster, and must be supported by documentation to ensure expenses are proper. Condition: In the current year, the Organization failed to provide supporting documentation for 7 of 40 non-payroll cash disbursement selections, and we were unable to determine if the cost/activity was allowable/unallowable. Cause: Due to the transfer of operations beginning on July 1, 2024, to a new LWDB, turnover within the LWDB, and movement to a new office, the LWDB was not able to provide supporting documentation to substantiate the cost/activity. Effect: The Organization was not to provide documentation of the Allowable Cost/Activity requirements being met under the WIOA grant for 7 selections. Recommendation: We recommend that the Organization ensure proper documentation as required by WIOA is retained and accessible to document compliance with grant requirements. Response: Management concurs with the finding and recommendation. Due to the transfer of operations beginning on July 1, 2024, to a new LWDB, turnover within FL Crown, and movement to a new office, FL Crown was not able to provide supporting documentation to substantiate the cost/activity for 7 of 40 disbursement samples. The new consolidated entity, LWDB 26, through its Fiscal Agent, Alachua County and Alachua County Clerk of Court has robust controls in place to track all invoices and payments and the related supporting documentation. All the documentation is maintained in electronic workflows and stored within the ERP financial software system.