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TANF Summer Youth Camp. Subaward Compliance Overview Cliff Marsh FCDJFS Department Auditor March 7, 2012. Areas of Review. Internal Controls Payroll Allowability Allocability Subcontracts Subaward Terms. Internal Controls.
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TANF Summer Youth Camp Subaward Compliance Overview Cliff Marsh FCDJFS Department Auditor March 7, 2012
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
AllocabilityDirect and Indirect Expenses • Must be allowable • Must have a reasonable, documented basis • Must represent FCDJFS’ “fair share”
AllocabilityDirect Expenses • Included in the budget • Provide direct services for program participants • Supported by a Cost Allocation Plan • “Fair Share” for FCDJFS
AllocabilityIndirect Expenses • Supported by Indirect Cost Plan • Properly allocated to FCDJFS grant based on period of allowability and benefit to subaward participants
SubcontractsLeases 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? • http://www.franklincountyohio.gov/commissioners/jafs/ • Related Links • FCDJFS Subrecipient and Vendor Compliance Tools