STATE OF WEST VIRGINIA DEPARTMENT OF HEALTH AND HUMAN RESOURCES GRANTEE AUDIT COMPLIANCE GUIDE [To assist grantees in complying with the Federal audit, disclosure and State accountability requirements referenced within Exhibit F of the DHHR grant agreement] Revised August 2010 West Virginia Department of Health and Human Resources Deputy Secretary for Administration One Davis Square, Suite 300 Charleston, WV 25301 Telephone: 304-558-5208 Fax: 304-558-1003
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West Virginia Department of Health and Human … OF WEST VIRGINIA DEPARTMENT OF HEALTH AND HUMAN RESOURCES GRANTEE AUDIT COMPLIANCE GUIDE [To assist grantees in complying with the
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STATE OF WEST VIRGINIA DEPARTMENT OF HEALTH AND
HUMAN RESOURCES
GRANTEE AUDIT COMPLIANCE GUIDE
[To assist grantees in complying with the Federal audit, disclosure and State accountability requirements referenced within Exhibit F of the DHHR grant agreement]
Revised August 2010
West Virginia Department of Health and Human Resources Deputy Secretary for Administration
EXHIBIT F FEDERAL AUDIT REQUIREMENTS – STATE ACCOUNTABILITY REQUIREMENTS GRANTEE AUDIT CERTIFICATION AND FEDERAL EXPENDITURE DISCLOSURE
DHHR FINANCE-180 REVISED 03/09 PAGE 1 OF 1 GRANT AGREEMENT WEST VIRGINIA DEPARTMENT OF HEALTH AND HUMAN RESOURCES G#000000
F.1. Office of Management and Budget (OMB) Circular A-133
: Grantees that expend $500,000 or more during their fiscal year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of the United States Office of Management and Budget’s (OMB) Circular A-133, Audits of States, Local Governments and Nonprofit Organizations. The OMB Circular A-133 audit and related reporting package described therein shall be submitted to the Office of Internal Control and Policy Development, Division of Compliance and Monitoring at the address referenced below within the earlier of 30 days after receipt of the auditor’s report(s) or nine months after the Grantee’s fiscal year end.
F.2. Grantee Audit Certification and Federal Expenditure Disclosure (GACFED) form
: The DHHR developed a Grantee Audit Certification and Federal Expenditure Disclosure (GACFED) form to track the Grantee’s total Federal award expenditures and to ensure that its Grantees comply with the Federal audit requirements of OMB Circular A-133. Specifically, the GACFED form provides the DHHR with precise information related to a Grantee’s Federal award activity in advance of the OMB Circular A-133 audit due date. The Grantee shall submit the GACFED form to the Office of Internal Control and Policy Development, Division of Compliance and Monitoring at the address referenced below within 60 days after the Grantee’s fiscal year end.
F.3. West Virginia Code §12-4-14
: West Virginia Code Chapter 12, Article 4, Section 14 (§12-4-14) sets forth grant-related accountability requirements enacted by the West Virginia Legislature. West Virginia Code §12-4-14 requires any person, corporation, partnership, association, individual or other legal entity that receives one or more State grants in the amount of $50,000 or more in the aggregate in a State’s fiscal year to file with the grantor(s) a “report” of the disbursement of the State grant funds. Conversely, persons or organizations receiving less than $50,000 in the aggregate must submit a Sworn Statement of Grant Receipts and Expenditures made under the grant(s). Grantees must submit the required report(s) referenced in West Virginia Code §12-4-14 to the Office of Internal Control and Policy Development, Division of Compliance and Monitoring within two years after the end of the fiscal year in which the DHHR disbursed the State grants to the Grantee. According to the Code, if the Grantee’s fiscal year differs from the State’s fiscal year (July 1 through June 30), the Grantee must file required reports and sworn statements within two years after the end of the Grantee’s fiscal year following the State fiscal year in which the funds were disbursed.
F.4. Source of Funds
individual award documents, regardless of grantor, when determining the most efficient and effective means to meet the submission requirements referenced within this grant agreement and possibly attached to other grant awards. Please note that the source of funds schedule, attached to the DHHR grant agreement as Exhibit B, identifies the source (origin) of funds to be used as payment for the term of this grant. Federal funding retains its identity even when it is sub-granted (passed-through) to other organizations; hence, Federal funds are identified in the source of funds schedule within this grant agreement by the applicable Catalog of Federal Domestic Assistance (CFDA) number(s) and the appropriated Federal revenue fund account number(s). State funds are identified by the specific appropriated general revenue fund and/or appropriated/non-appropriated special revenue fund account number(s).
: The relevant audit and reporting requirements expressed within this Exhibit and applicable to DHHR Grantees are generally contingent upon the collective award amounts and related requirements attached to the original funding source. Therefore, it is imperative that both Grantees and their external auditors know the original source of grant funds in order to properly plan, procure and perform an audit or attestation service or to otherwise meet applicable reporting requirements referenced within this Exhibit. In addition to this grant agreement, Grantees should review all other
F.5. Address for Submission
WV Department of Health and Human Resources Office of Internal Control and Policy Development
Division of Compliance and Monitoring One Davis Square
Suite 401 Charleston, WV 25301
Questions pertaining to this Exhibit may be directed to the Office of Internal Control and Policy Development, Division of Compliance and Monitoring at 304-558-9919 or via facsimile to 304-558-2269.
: Grantees shall submit all audits, reports and supporting information and documentation, whether directly stated or implicitly referenced within this Exhibit, to the following address:
F.6. Penalties for Noncompliance
: In cases of the Grantee’s inability or unwillingness to comply with the audit, reporting and disclosure requirements referenced within this Exhibit, the DHHR shall take appropriate action against the Grantee via one or more of the following sanctioning measures: withholding grant funds, suspending grant payments, terminating grant awards, debarring the Grantee from receiving future grants.
F.7. Grantee Audit Compliance Guide / Internet Links: The DHHR developed a Grantee Audit Compliance Guide to further describe and to assist its grantees in complying with the audit, reporting and related disclosure requirements applicable to DHHR grant awards. The Grantee Audit Compliance Guide is posted on the Internet and may be accessed by going to www.wvdhhr.org and then clicking the applicable link on the left side of the webpage. In addition to the Grantee Audit Compliance Guide, the DHHR webpage includes a copy of the GACFED form required by Section F.2 of this Exhibit, links to certain regulatory documents such as OMB Circular A-133 and WV Code §12-4-14, and various other forms and tools to ensure compliance with the requirements referenced herein. The Grantee Audit Compliance Guide applies specifically to recipients of grant awards (Grantees) from the DHHR and must be read in its entirety to gain a complete and thorough understanding of the individual audit and reporting requirements applicable to DHHR grant agreements.
DHHR Grantee Audit Compliance Guide Attachment A - Exhibit F of the WV DHHR Grant Agreement
DHHR Grantee Audit Compliance Guide Attachment B - Grantee Audit Certification and Federal Expenditure Disclosure (GACFED) Form
PLEASE REFER TO WW
W.W
VDHHR.ORG/OAMR/GRANTEEAUDITCOM
PLIANCEGUIDE FOR CURRENT GACFED FORM AND INSTRUCTIONS
Grant Number:
WVFIMS Vendor #:
Invoice Number Invoice Period Covered Invoice Amount Date Received Amount Received
$0.00
Amount Expended
$0.00
$0.00
Authorized Signature: Date:
Printed Name and Title:
Notary Public Signature:
My Commission Expires:
Revised 03/09
West Virginia Department of Health & Human ResourcesSworn Statement of Grant Receipts and Expenditures
Total Grant Amount:
Grantee Mailing Address:
Contact Phone Number:
Period Covered:
(Please see the Instructions for Completion of the Sworn Statement of Grant Receipts and Expenditures located in the Grantee Audit Compliance Guide as Attachment D)
Grantee Name:
Grantee FEIN:
expenditure of funds granted by the State of West Virginia, Department of Health and Human Resources to 0
Taken, sworn and subscribed before me this____ day of ____________, 20____.
by our financial records and related documentation.of Grant Receipts and Expenditures is presented on the
Total Grant Expenditures
This is to certify that I have reviewed the Statement of Grant Receipts and Expenditures submitted herewith and, to the best of my knowledge and belief, said statement represents all financial activities related to the receipt, use and
and that the expenditures reported were for the purposes intended and in compliance with the applicable laws, regulations and terms and conditions of the grant documents. The Statement
basis of accounting and is supported
Ending Funds Balance (Receipts – Expenditures)
Indirect Cost
Professional Service Costs
Telephone, Utilities
Description/Examples
Salaries and Wages
Office Supplies, Postage, TrainingMaterials and Supplies
Other
Subgrants
Rental Costs
Contracts, Consultants
Office Space, Equipment
Equipment and Other Capital Expenditures
Grant Receipts
Total Grant Receipts
Grant ExpendituresExpenditures
Personnel
Fringe Benefits
DHHR Grantee Audit Compliance Guide Attachment C - Sworn Statement of Grant Recepts and Expenditures Form
PLEASE REFER TO WW
W.W
VDHHR.ORG/OAMR/GRANTEEAUDITCOM
PLIANCEGUIDE FOR CURRENT SOE FORM AND INSTRUCTIONS
Revised 08/10
West Virginia Department of Health and Human Resources Instructions for Completion of the Sworn Statement of Grant Receipts and Expenditures
To ensure completeness and consistency in accounting for state funds under West Virginia Code §12-4-14, Accountability of persons receiving state funds or grants; sworn statements by volunteer fire departments; criminal penalties, the West Virginia Department of Health and Human Resources (DHHR) has developed a standardized Sworn Statement of Grant Receipts and Expenditures, which shall be the mandatory format (layout) for all such submissions to the DHHR. All fields within the Sworn Statement of Grant Receipts and Expenditures must
be completed to ensure that the submission meets applicable reporting requirements.
Please make sure that a separate Sworn Statement of Grant Receipts and Expenditures is submitted for each applicable “state grant”. It should be noted that for purposes of West Virginia Code §12-4-14, the term "state grant" does not include Federal pass-through funds that are subject to the Federal Single Audit Act Amendments of 1996, 31 U. S. C. 7501, et seq. Nevertheless, the reporting requirements do not prohibit the reporting of these funds and Grantees who receive an award with a mixture of State and Federal funds may choose to report the collective amounts under the grant receipts and expenditures. Grant Number – Enter the grant agreement number for which the information is being reported. The DHHR issued grant number is provided in the grant agreement using the following format G######. Only one individual grant number may be reported on each Sworn Statement of Grant Receipts and Expenditures. Grantee Name – Enter the name of the organization reporting its grant receipts and expenditures. In order to ensure consistency, this entry should match the Grantee name provided within the applicable DHHR grant agreement. Grantee FEIN – Enter the Grantee’s Federal Employer Identification Number (FEIN) as presented within the applicable DHHR grant agreement. Grantee WVFIMS Vendor Number – Enter the Grantee’s WVFIMS Vendor number as presented within the applicable DHHR grant agreement. Contact Phone Number – Enter a contact number where questions concerning the Sworn Statement of Grant Receipts and Expenditures may be addressed. Grantee Mailing Address – Enter the current mailing address of the Grantee. Total Grant Amount – Enter the total amount of the DHHR grant award. This number should reflect the final award amount and may include any Federal Funds received and/or any changes or adjustments to the original award. Period Covered – Enter the period (MM/DD/YY – MM/DD/YY) for which the Grantee is reporting grant receipts and expenditures. The Grantee is allotted the discretion to report on the period that provides the most accurate and complete information. For example, if the grant period does not match the Grantee’s fiscal year, the Grantee may choose to report the information on either the grant period or fiscal year methodology. When possible, it is recommended that the Grantee select a period of time that encompasses the entire financial activity of the applicable grant so that the reporting requirements can be satisfied with one submission.
Reporting Grant Receipts Invoice Number – Enter an identifying number for each invoice submitted to DHHR for payment. In cases where there was no specific invoice number assigned, the Grantee may simply utilize a sequential numbering method. Invoice Period Covered – For each invoice number enter the period of expenses covered. Invoice Amount – Enter the amount invoiced by the Grantee.
DHHR Grantee Audit Compliance Guide Attachment D - Instructions for the Sworn Statement of Grant Receipts and Expenditure Form
PLEASE REFER TO WW
W.W
VDHHR.ORG/OAMR/GRANTEEAUDITCOM
PLIANCEGUIDE FOR CURRENT SOE FORM AND INSTRUCTIONS
Revised 08/10
Date Received – Enter the date that grant funds were received for each invoice. Amount Received – Enter the amount of funds received for each invoice number. *Total Grant Receipts – Add up the individual invoice receipt amounts and enter the total amount of grant funds received.
Reporting Grant Expenditures DHHR grant agreements require that a detailed budget and justification worksheet (budget) be prepared and approved for all grants and related agreements negotiated with the DHHR. In accordance with those requirements, Grantees are required to report grant expenditures under the Sworn Statement of Grant Receipts and Expenditures using the same budget line items. Amount Expended – Enter the amount of funds expended under each of the budget line items listed within the Sworn Statement of Grant Receipts and Expenditures. *Total Grant Expenditures - Add up the individual line-item expenditure amounts and enter the total amount of grant funds expended. *Ending Funds Balance – Subtract the Total Grant Expenditures from the Total Grant Receipts and enter the final amount. Please note: If the Ending Fund Balance is greater than zero, the Grantee is attesting that their grant receipts were in excess of grant expenditures and may be subject to repayment to the DHHR.
Notarized Sworn Statement Sworn Statement - To complete the sworn statement, the Grantee is required to re-enter the Grantee Name and provide the basis of accounting on which the financial information is presented (e.g. accrual basis or cash basis) Authorized Signature – A senior representative of the Grantee who has the authority to bind the Grantee must sign the Sworn Statement of Grant Receipts and Expenditures. Date – Enter the date of the Authorized Signature. Printed Name and Title – Enter the printed name and title of the person providing the Authorized Signature. Notary Public Signature – The Authorized Signature shall be notarized by a certified notary public in good standing with the Secretary of State.
Submission of the Sworn Statement of Grant Receipts and Expenditures Form
Questions regarding completion of the Sworn Statement of Grant Receipts and Expenditures form shall be directed to the address, telephone or fax number referenced below. The Grantee shall submit the Sworn Statement of Grant Receipts and Expenditures form by the required deadline to the following address:
WV DHHR Office of Internal Control and Policy Development Division of Compliance and Monitoring
One Davis Square, Suite 401 Charleston, WV 25301
Telephone: 304-558-9919 Fax: 304-558-2269
* The writable PDF version of the Sworn Statement of Grant Receipts and Expenditures will automatically total these amounts.
DHHR Grantee Audit Compliance Guide Attachment D - Instructions for the Sworn Statement of Grant Receipts and Expenditure Form
PLEASE REFER TO WW
W.W
VDHHR.ORG/OAMR/GRANTEEAUDITCOM
PLIANCEGUIDE FOR CURRENT SOE FORM AND INSTRUCTIONS
West Virginia Department of Health and Human Resources Supplemental Compliance Procedures for an Agreed-Upon Procedures Engagement Conducted in
Accordance with West Virginia Code §12-4-14 and CSR §148-18 A.
Purpose
To maintain uniformity and consistency among DHHR grantees and their independent CPAs when arranging for and conducting an agreed-upon procedure engagement in accordance with the reporting requirements of West Virginia Code §12-4-14.
B.
Applicability
The supplemental compliance procedures contained herein were developed for and intended to be applicable to DHHR grant awards only and should be read in conjunction with West Virginia Code §12-4-14, CSR §148-18 and the related grant documents (e.g. grant agreement, statements of work, budgets, change orders, program directives, regulations, etc.). These procedures should not be applied to grant funds awarded by other state agencies or spending units.
Regarding Compliance Attestation Standards, it is strongly recommended that grantees discuss with their independent CPAs the costs and variable differences between arranging for an agreed-upon procedures engagement versus an examination engagement, before determining how to best satisfy the reporting requirements of West Virginia Code §12-4-14.
C.
Procedures to be Performed – Grantees
Prepare a sworn statement of expenditures, to include all of the elements referenced in CSR §148-18-5 and the following written management assertion:
“This is to certify that I have reviewed the Statement of Grant Receipts and Expenditures submitted herewith and, to the best of my knowledge and belief, said statement represents all financial activities related to the receipt, use and expenditure of funds granted by the State of West Virginia, Department of Health and Human Resources to [GRANTEE NAME] and that the expenditures reported were for the purposes intended and in compliance with the applicable laws, regulations, and terms and conditions of the grant documents. The Statement of Grant Receipts and Expenditures is presented on the [ACCRUAL / CASH] basis of accounting and is supported by our financial records and related documentation.”
D.
Procedures to be Performed – Independent Certified Public Accountants
1. Review the grant agreement and any related documents (e.g. statements of work, budgets, change orders, program directives, regulations, etc.) to ascertain the purpose for which the funds were awarded and the terms and conditions associated with the state grant.
2. Verify whether funds received under the grant (as reported on the sworn statement of expenditures)
were correctly authorized, recorded and deposited into the appropriate organizational accounts.
3. Review all costs (as listed on the sworn statement of expenditures) and related transactions associated with the grant to verify whether:
a. Costs were approved by the DHHR, if required.
b. Costs conform to the allowability of costs provisions or limitations in the program agreement,
program regulations, or program statute.
c. Costs represent charges for actual costs, not budgeted or projected amounts.
DHHR Grantee Audit Compliance Guide Attachment E - Supplemental Compliance Procedures for an Agreed-Upon Procedures Engagement
d. Costs are given consistent treatment within and between accounting periods. Consistency in
accounting requires that costs incurred for the same purpose, in like circumstances, be treated as either direct costs only or indirect costs only with respect to final cost objectives.
e. Costs are net of all applicable credits (e.g. volume or cash discounts, insurance recoveries, refunds,
rebates, trade-ins, adjustments for checks not cashed, and scrap sales.).
f. Costs are not included as both a direct billing and as a component of indirect costs.
g. Cost are supported by appropriate documentation (e.g. approved purchase orders, receiving reports, vendor invoices, canceled checks, and time and attendance records), and correctly charged as to account, amount and period.
4. Inquire and report upon the status of any findings, contingencies or other deficiencies discovered during
the current engagement or described in any prior agreed-upon procedures report (if applicable) that could negatively affect administration of the DHHR grant and related program/project.
DHHR Grantee Audit Compliance Guide Attachment E - Supplemental Compliance Procedures for an Agreed-Upon Procedures Engagement
WEST VIRGINIA CODE §12‐4‐14 Due Dates for Submission of Required Reports and Sworn Statements of Grant Receipts and Expenditures
If the Grantee received “state grants” during the following period
And the Grantee’s fiscal year end date is
Then the Grantee must submit its required “report” and/or sworn statement of grant receipts and
expenditures before
07/01/09 – 06/30/10
06/30/10 06/30/12
07/31/10 07/31/12
08/31/10 08/31/12
09/30/10 09/30/12
10/31/10 10/31/12
11/30/10 11/30/12
12/31/10 12/31/12
01/31/11 01/31/13
02/28/11 02/28/13
03/31/11 03/31/13
04/30/11 04/30/13
05/31/11 05/31/13
If the Grantee received “state grants” during the following period
And the Grantee’s fiscal year end date is
Then the Grantee must submit its required “report” and/or sworn statement of grant receipts and
expenditures before
07/01/10 – 06/30/11
06/30/11 06/30/13
07/31/11 07/31/13
08/31/11 08/31/13
09/30/11 09/30/13
10/31/11 10/31/13
11/30/11 11/30/13
12/31/11 12/31/13
01/31/12 01/31/14
02/28/12 02/28/14
03/31/12 03/31/14
04/30/12 04/30/14
05/31/12 05/31/14
If the Grantee received “state grants” during the following period
And the Grantee’s fiscal year end date is
Then the Grantee must submit its required “report” and/or sworn statement of grant receipts and
expenditures before
07/01/11 – 06/30/12
06/30/12 06/30/14
07/31/12 07/31/14
08/31/12 08/31/14
09/30/12 09/30/14
10/31/12 10/31/14
11/30/12 11/30/14
12/31/12 12/31/14
01/31/13 01/31/15
02/28/13 02/28/15
03/31/13 03/31/15
04/30/13 04/30/15
05/31/13 05/31/15
If the Grantee received “state grants” during the following period
And the Grantee’s fiscal year end date is
Then the Grantee must submit its required “report” and/or sworn statement of grant receipts and
expenditures before
07/01/12 – 06/30/13
06/30/13 06/30/15
07/31/13 07/31/15
08/31/13 08/31/15
09/30/13 09/30/15
10/31/13 10/31/15
11/30/13 11/30/15
12/31/13 12/31/15
01/31/14 01/31/16
02/28/14 02/28/16
03/31/14 03/31/16
04/30/14 04/30/16
05/31/14 05/31/16
DHHR Grantee Audit Compliance Guide Attachment F - Due Dates for WV Code §12-4-14 Reporting