financial procedures manual - workforceresource.org

Revised: 03-13-12

Workforce Resource, Inc. - Workforce Development Board

FINANCIAL PROCEDURES MANUAL

WORKFORCE RESOURCE, INC. - WORKFORCE DEVELOPMENT BOARD


Revised: 03-13-12

Table of Contents

Table of Contents i Forward ii

PROCEDURES................................................................................................................................................................. 1 SECTION I. GENERAL ....................................................................................................................................... 2 SECTION II. CASH ADVANCE REQUESTS ...................................................................................................... 3 SECTION III. CASH RECEIPT AND HANDLING ............................................................................................... 4 SECTION IV. CASH DISBURSEMENTS ........................................................................................................... 7 SECTION V. ADMINISTRATIVE PURCHASING ............................................................................................. 10 SECTION VI. PAYROLL ................................................................................................................................... 15 SECTION VII. TRAVEL .................................................................................................................................... 18 SECTION VIII. WRI, WDB AND LEO BOARD MEMBER EXPENSES ............................................................ 22 SECTION IX. PROPERTY ................................................................................................................................ 23 SECTION X. LEASES ...................................................................................................................................... 26 SECTION XII. TELEPHONES, PHOTOCOPY AND FAX MACHINES ............................................................ 28 SECTION XIII. CONSULTANTS ...................................................................................................................... 30 SECTION XIV. GRANTS AND CONTRACTS .................................................................................................. 31 SECTION XV. BUDGETS................................................................................................................................. 32 SECTION XVI. BOOKS OF ORIGINAL ENTRY ............................................................................................... 33 SECTION XVII. REPORTS............................................................................................................................... 34 SECTION XVIII. MATCHING FUNDS, NONFEDERAL IN-KIND CONTRIBUTIONS, AND STAND-IN COSTS

.............................................................................................................................................................. 35 SECTION XIX. COST ALLOCATION PLAN ..................................................................................................... 37 SECTION XX. OTHER ..................................................................................................................................... 38 SECTION XXI. COMPUTER CONTROLS AND SECURITY ........................................................................... 39 SECTION XXII. AUDIT ..................................................................................................................................... 40 SECTION XXIII. PROGRAM INCOME ............................................................................................................. 43

FORMS ........................................................................................................................................................................... 45

Pages numbers on this page represents those shown in the lower right corner of each page. Each section also includes page numbers (e.g. Page 1 of 2).

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Revised: 03-13-12

Forward The Workforce Resource, Inc. (WRI) was initially formed as a Private Industry Council (PIC) following the enactment of the Job Training Partnership Act (JTPA, PL 97-300) of 1982. The WRI organization (whose Board is composed of membership from both the County Board's Consortium-LEO/CBC and the Workforce Development Board-WDB) became officially recognized by the Wisconsin Departments of State and Revenue as a private-nonprofit, tax exempt corporation under Chapter 181 of the Wisconsin State Code on October 3, 1983. The WRI organization acting as fiscal agent for and under direction of the West Central Wisconsin WDB (formerly West Central Wisconsin Private Industry Council, Inc.-PIC), is recognized by the Internal Revenue Service as a 501(c)3 and, tax exempt by the Local, State, and Federal taxing authorities. Throughout the organization's tenure, its corporate mission was expanded "to mobilize and focus available community resources" as directed within the confines of the WRI-WDB. This corporate mission allowed the WRI to establish a local presence in each county of the program delivery-workforce development area. Various targeted funding sources are used in concert to deliver employment and training services at local county-based Job Center offices. This program and delivery system emphasis continues under subsequent legislation (such as, Workforce Investment Act (WIA), Wisconsin Works and various other and related funding authorities. Recognizing the strong legislative requirements and sound accounting principles (GAAP, A-133, SSAG/PAAG, GAS, the yellow book, State Single Audit Act, etc.) involved in managing and documenting financial processes and transactions of the organization, the WDB/WRI has established this Financial Procedures Manual. The most current organizational chart and office directory follows Section I. Respectfully, Richard J. Best Executive Director

Revised: 03-13-12

PROCEDURES



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SECTION I. GENERAL 1. The Workforce Development Board (WDB) designates Workforce Resource, Inc. (WRI) as fiscal agent for the

WDB and its resources. The Workforce Resource, Inc. (WRI) formulates overall financial policies, delegates administration of the financial policies to the administrative staff, and reviews all agency operations and activities within parameters established by the WDB.

2. Executive Director has responsibility for all operations and activities, including financial management. 3. Chief Financial Officer is responsible to Executive Director for all financial operations. 4. The lines of authority on the agency's organizational chart will be followed by all employees. 5. Current job descriptions will be maintained for all employees indicating duties and responsibilities. 6. Financial duties and responsibilities must be separated so that no one employee has sole control over cash

receipts, disbursements, payrolls, reconciliation of bank accounts, etc. 7. All employees are to take annual vacations per personnel policy. 8. Separate accounts and books will be maintained as required by funding source regulations. 9. All forms will be completed in ink. The use of white-out when correcting forms will be discouraged. 10. Every effort will be made to ensure, to the extent practical, that all FINANCE positions are cross-trained and

backed up with other workers in the department and organization. These "back-up" positions will perform the primary and required functions while a position is vacant (vacation, other leave, etc.) and contribute to the maintenance of effective internal controls.

11. Fiscal and accounting procedures are generally in accordance with recognized generally accepted accounting

principles (GAAP) for the organization. Where there are differences from GAAP, such as charging the full amount of equipment to grants rather than depreciating them, notations will appear in the organization's audit report.

12. Accounting records must adequately identify the source and application of funds and be properly supported by

source documentation (electronic copies are kept using Sentry File as established in consultation with the State DWD acting on behalf of the DOL). These records must contain information about awards, authorization, revenues, expenditures, accruals (as required by WIA AND OTHER FUNDING AUTHORITIES), obligations and unobligated balances by fund. The records must be sufficient to permit the: a. preparation of required reports; b. tracing of funds to a level of expenditure adequate to establish that funds have not been used in

violation of the applicable restrictions on the use of such funds; c. tracing of program incomes, potential stand-in costs and other incurred costs that are otherwise

allowable except for funding limitations; and d. demonstration of compliance with applicable matching requirements.

Page 1 of 1 Date Effective: July 1, 2008 Date Revised: February 1, 2012



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SECTION II. CASH ADVANCE REQUESTS 1. WIA AND OTHER FUNDING AUTHORITIES cash in the WDA and subrecipient financial systems will be kept

at a minimum and will be managed in compliance with DWD Administrative Assurances and Requirements. 2. The DWD Invoice or Request for Payment (for use with CORE) will be prepared by the Chief Financial Officer

or Financial Services Coordinator based on the immediate cash needs of the WRI and subcontractors, if any. Factors considered when anticipating immediate cash needs include, but are not limited to:

a. Unpaid invoices on hand; b. Estimated salaries/wages and fringes; c. Rent; d. Advances/reimbursements to subrecipients; e. Estimated other costs (OJT reimbursements, needs based/related payments, purchase of

service/payment authorizations, etc.). 3. The Executive Director or designee will review and approve all cash advance/reimbursement requests made

to DWD. 4. The WRI's Invoice or Request for Advance or Reimbursement will be prepared by subcontractors and

submitted to WRI for payment. 5. The Financial/Accounts Payable Specialist will prepare the Payment Voucher for subcontractor payments and

submit it to the Chief Financial Officer or Financial Services Coordinator for payment authorization or approval. 6. The Regional Coordinator (or other designated Program Manager) and the Chief Financial Officer or designee

will review and approve all advance/reimbursement requests made by the subcontractors. 7. The Financial/Accounts Payable Specialist will process subcontractor payments via the ORION Accounts

Payable Program after the Chief Financial Officer's or designee's approval. 8. The Financial/Accounts Payable Specialist (or designee) will double check payments to subcontractors

against payment vouchers and backup prior to mailing them. If problems exist with said payments, return to Step 4 for remediation by Financial/Accounts Payable Specialist. The Financial/Accounts Payable Specialist will keep a three-ring notebook of the most recent invoice paid by subcontractor and compare totals by cost category with the general ledger.

9. The Regional Coordinator (or other designated Program Manager) will receive subgrantee financial system

reports on a monthly basis for monitoring purposes and to assure accuracy/completeness of the data inputs. 10. The Chief Financial Officer or Financial Services Coordinator prepares the back up worksheet based on

information received from the Financial/Accounts Payable Specialist and the Financial/Payroll Specialist for the DWD Invoice or Request for Payment (CORE related). (The back up worksheet is used to monitor and compare estimated cash needs by expense item and actual expenses and the Cash Receipts and Disbursements Record includes all WIA and non-WIA cash and shows how it flows through the WRI's bank accounts, when it is received, deposited in savings account, transferred to checking accounts and disbursed.)

11. Cash Advance Requests will be processed for non-WIA funding sources whenever possible and feasible

(weekly or monthly as the program allows). 12. WIA contracts are usually reimbursement contracts only. Therefore, the WRI advances money to WIA

programs for expenses and are later reimbursed (therefore, negative cash balance exit for WIA).

Page 1 of 1 Date Effective: July 1, 2011 Date Revised: March 13, 2012



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SECTION III. CASH RECEIPT AND HANDLING Cash Receipt and Handling - Central 1. All cash and checks will be received and receipted by the person opening the mail, the Office Manager or

designee, and then forwarded to the FINANCE Department. DWD and Federal government checks are most often mailed or sent via electronic funds transfer (EFT) directly to and deposited by Dairy State Bank of Menomonie, Wisconsin in appropriate accounts.

2. All receipted cash and checks will be deposited to the Money Market Investment Account (when available and

is referred to as the "savings" account and may be run in conjunction with a repurchase agreement, as necessary) at the Dairy State Bank of Menomonie by Financial/Accounts Payable Specialist or designee. [If interest bearing accounts are not available with 100% of dollars FDIC or collaterally secured then interest will not be earned.]

3. All receipts will be deposited intact. 4. All checks will be endorsed, "Pay to the Order of Dairy State Bank, Menomonie, Wisconsin" or "West Central

Wisconsin Workforce Resource, FOR DEPOSIT ONLY, Account XXXXXXX" or other acceptable designation. 5. Documentation for all receipts will be filed by month in the FINANCE Department. 6. Upon verification of the deposit, the Financial/Accounts Payable Specialist records all receipts on the Daily

Cash Balance Record. 7. The Financial/Accounts Payable Specialist records appropriate revenue-related journal entries in the ORION

Financial System. 8. The Chief Financial Officer or designee scans and approves journal entries to ensure that the entry is done in

an appropriate manner and that the necessary supporting documentation is attached. Cash Receipts and Handling - Local Offices 1. All cash and checks will be received by the Field Office Secretary or designee. 2. The fee-for-service contracting and billing processes requires payments to be sent to central. This limits the

number of times checks are handled by local and central offices. 3. Cash and/or checks received at local field offices should be handled as defined in the petty cash process

shown below. 4. No cash should be mailed by field offices to central. Petty Cash 1. The following petty cash boxes will be maintained by the agency:

Office Custodian Amount Central Office Manager $50.00 Barron Field Office Secretary $50.00 Chippewa Field Office Secretary $50.00 Clark Field Office Secretary $50.00 Dunn Field Office Secretary $50.00 Eau Claire Field Office Secretary $50.00 Pepin Field Office Secretary $50.00 Barron International Field Office Secretary $50.00 Polk Field Office Secretary $50.00 St. Croix Valley Field Office Secretary $50.00

Page 1 of 2 Date Effective: April 1, 2011 Date Revised: February 1, 2012



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2. Each staff person having access log additions or deletions to the petty cash fund. No loans will be made from petty cash funds.

3. All petty cash funds will be kept in a locked petty cash box in a locked drawer or file cabinet. Only the petty

cash custodian and their direct supervisor (or designee) will have keys to the petty cash box, drawer, and cabinet.

4. Payments of up to fifty dollars can be made from the petty cash fund for making change for customers and/or

other necessary disbursements as made within the parameters of the criteria listed in point 7 below. 5. All checks received by the local office will be receipted and immediately forwarded to the Central FINANCE

`Department, stamped, "West Central Wisconsin Workforce Resource, FOR DEPOSIT ONLY, Account XXXXXXX." Cash receipts at local offices will be immediately receipted and put in the cash lock box. Numbered cash receipt books will be used as needed within the petty cash register process citing the number for each written receipt.

6. Cash in excess of seventy-five dollars will be brought before close of business each day, converted into a

bank draft and sent to the WRI Central FINANCE Department. The cost of the bank draft will be deducted from petty cash and the petty cash register.

7. At local offices, Workforce Resource Coordinators will determine if advance authorization is required for petty

cash disbursements. Workforce Resource Coordinators approve expenditures using the following criteria: The proposed expenditure is:

* less than fifty dollars; and * required for smooth operation of the local office; and * not otherwise available via the Central Supply or similar process, in a timely enough manner; and/or * needed to meet an allowable emergency situation.

8. The purchaser will present the petty cash disbursement slip (see Petty Cash Slip), approved by the Workforce

Resource Coordinator, to the petty cash fund custodian for payment. A sales receipt for all purchases must be attached to the petty cash slip.

9. The petty cash custodian will insure that the petty cash slip is properly completed, approved, and that a proper

receipt (from cash receipt book, if needed, and sales receipt as referenced in point 9) is attached before payment is made.

10. When the petty cash fund falls below a balance of fifteen dollars, the petty cash custodian will submit the

recap of all receipts and disbursements to the WRI Central FINANCE Department for reimbursement. 11. Petty cash reimbursement checks will be made payable to the Petty Cash Custodian's name (i.e. "Employee

Name, Petty Cash Custodian"). 12. The Workforce Resource Coordinator or designee will conduct surprise counts of all petty cash funds. 13. Any irregularities in the petty cash fund will be immediately reported in writing to the Chief Financial Officer or

Financial Services Coordinator.


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Petty Cash Slip

Date:_____________________ Check One:

___ Cash Received ___ Check Received ___ Disbursement

(attach receipts) Amount:______________________________________________ From whom:__________________________________________ For what:_____________________________________________ Received by:__________________________________________ Workforce Resource Coordinator:_______________________ Petty Cash Custodian:_________________________________

Petty Cash Slip

Date:_____________________ Check One:



Petty Cash Slip

Date:_____________________ Check One:



Petty Cash Slip

Date:_____________________ Check One:



Petty Cash Slip

Date:_____________________ Check One:



Petty Cash Slip

Date:_____________________ Check One:





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SECTION IV. CASH DISBURSEMENTS General 1. All original invoices will be immediately forwarded to the FINANCE Department. 2. Accounts Payable Vouchers will be paid regularly each week. 3. Checks will be compared and verified by the Financial/Accounts Payable Specialist or designee with vouchers

before mailing and check copies attached to the voucher. Incorrect checks will be voided and replacement checks issued when necessary.

4. "Voided" checks (including preparation spoilage) will be handled as follows:

a. "Voided" checks will be separated from good checks to be signed.

b. "Voided" checks including copies will have "VOID" boldly written in ink or stamped across the face of check.

c. The signature portion of the original of "VOIDED" check will be perforated or cut out.

d. The yellow copy of "Voided" checks will be filed in numerical order in a "Voided" check file.

e. "Voided" checks will be entered into the General Ledger System by the assigned Financial/Payroll

Specialist. 5. FINANCE staff prepare and enter appropriate journal entries to record adjustments to disbursements on the

General Ledger System. 6. The assigned Financial/Accounts Payable Specialist enters "Voided" check adjustments on the Daily Cash

Receipts and Disbursements Record, as necessary. 7. The Chief Financial Officer or designee scans and approves journal entries to ensure that the entry is done in

an appropriate manner and that the necessary supporting documentation is attached. Operational Vouchers 1. The assigned Financial/Accounts Payable Specialist will prepare a Payment Voucher for payment of invoices

issued by vendors. 2. Copies of required Purchase Orders and receiving/packing slips will be attached to Payment Vouchers as

necessary. 3. Vouchers will be approved by the Chief Financial Officer or designee prior to payment. Program Services Vouchers 1. All Needs Based/Related Payment Authorizations (NBRA) and Purchase of Service/Payment Authorizations

(POS) will be given to the assigned Financial/Accounts Payable Specialist. The forms used in this procedure may vary by program (WIA versus W2; Needs Based Payment Authorizations versus Needs Related Payment), but the overall process remains the same. See specific program procedures for differences in forms used.




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2. Each NBRA and POS will be checked by the assigned Financial/Accounts Payable Specialist for signatures and proper documentation.

3. Each NBRA and POS will be checked against each participant's file by the assigned case manager to

determine program, source and title to be charged. 4. The Eligibility Determination Form (EDF) of each participant will also be checked by the assigned case

manager to determine date of eligibility, which is the starting date that cost may be incurred. 5. The POS will be coded as to program, cost category and fund to be charged by the assigned

Financial/Accounts Payable Specialist. 6. The NBRA will be logged into the NBRA tracking system by person by the assigned Financial/Accounts

Payable Specialist so that time is not accidentally extended beyond the authorized period nor overpayment made.

7. Attendance sheets will be required as documentation for support service payments made from an NBRA. 8. The attendance sheets will be checked for needed signatures and documentation by the assigned

Financial/Accounts Payable Specialist. Manual Checks 1. Blank checks will be requisitioned from the Financial/Payroll Specialist or designee. (The individual

responsible for blank checks shall not be involved in the preparation of voucher input data, nor shall such individual have access to the key for the check signing machine.)

2. The check numbers of blank checks disbursed shall be entered on the Check Control Register, and the

individual receiving the checks will sign the register. 3. If any checks that have been disbursed are returned unused, the beginning and ending numbers will be

entered on the appropriate line of the Check Control Register. The beginning and ending numbers of the checks used will be posted, and the signature of the individual returning the checks will be obtained.

4. Checks will be prepared by the assigned Financial/Accounts Payable Specialist (or his/her backup). After all

checks have been written, any unused checks will be returned as explained above, and all checks written, voided and/or spoiled in preparation will be given to the Office Manager (or his/her designee) for signing, as necessary.

Check Signing 1. Checks will be signed by the Office Manager (or his/her designee) using ORION facsimile signature. All check

numbers used, including voided or spoiled checks, will be listed on the Check Signing Register. 2. The individual responsible for check signing will count the checks to be signed and verify the count with the

Check Signing Register. After the checks are signed, they will be returned to the person who prepared them. Bank Reconciliations 1. Bank Statements are given unopened to Chief Financial Officer or Financial Services Coordinator who

distributes them. 2. Savings and accounts payable bank account reconciliations are the responsibility of the Financial/Payroll

Specialist under review of the Chief Financial Officer or Financial Services Coordinator. The payroll bank account reconciliation is the responsibility of the Financial/Accounts Payable Specialist under review of the Chief Financial Officer or Financial Services Coordinator.

Page 2 of 3 Date Effective: November 1, 2008 Date Revised: February 1, 2012



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2. Bank reconciliations will be done on the checking accounts and the money market (referred to as "savings"

and includes transaction to/from the repurchase agreement, as necessary) account. 3. Bank reconciliations will be done monthly, in a timely fashion, after receipt of the statements from the bank. 4. All canceled checks will be filed numerically in the FINANCE Department by the Financial/Payroll Specialist.

The Financial/Payroll Specialist notifies the Financial/Accounts Payable Specialist or designee about outstanding checks. If checks are outstanding for two full months, the Financial/Accounts Payable Specialist or designee sends outstanding check letter to affected payee.

5. All bank reconciliations will be filed in the FINANCE Department by the Financial/Payroll Specialist.




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SECTION V. ADMINISTRATIVE PURCHASING 1. General

1. Code of Conduct

1. No administrative purchases of goods and/or services will be made for officers, employees, agents, or others intended for non-business purposes, or preference given in a competitive bid situation.

2. No member of any council or board, or committee thereof, nor LEO shall discuss or cast a

vote on any administrative purchase of goods or services from that member (or any organization which that member directly represents), or discuss or vote on any matter which would provide direct financial benefit to that member (or affiliated organization).

3. Any officer or public employee is guilty of a Class E felony when in her/his capacity as such

officer or employee, he/she participates in the making of a contract or purchase in which she/he has a private pecuniary interest, direct or indirect, or performs in regard to that contract or purchase some function requiring the exercise of discretion on her/his part.

4. The WRI prohibits its employees from using their positions for a purpose that is or that gives

the appearance of being motivated by a desire for private gain for themselves or those with whom they have family, business, or other ties.

5. The WRI and its personnel shall avoid organizational and personal conflict of interest and the

appearance of conflict.

6. No officer, employee, or agent of the WRI shall solicit or accept gratuities, favors or anything of monetary value from any person or organization in return for preferential treatment.

7. The WRI shall ensure that no individual is charged a fee for being referred to training or

placed in DWD or other publicly funded employment.

8. No board member, LEO, or employee of the WRI shall effectively recommend or decide to hire, promote, or establish the salary of another person when the person affected is a member of his or her immediate family. Furthermore, no board member, LEO or employee of the grantee shall give preferential treatment in the supervision or management of another employee who is a member of his or her immediate family.

Immediate family means wife, husband, son, daughter, mother, father, brother, brother-in-law, sister, sister-in-law, daughter-in-law, mother-in-law, father-in-law, aunt, uncle, niece, nephew, stepparent, and stepchild.

9. Violation of this code of conduct will result in disciplinary action, including, but not limited, to

suspension, termination, and/or criminal prosecution (see WRI personnel policies and master plan for additional detail).




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2. The following procurement standards are in force regardless of type of procurement:

1. Open and Free Competition including the requirement that for a particular procurement, the grantee who develops specifications, the statement of work, an invitation for bids, a request for proposal or evaluates or recommends such proposals may not be eligible to compete for the procurement. This applies to all types of contracts or grants.

2. A presumption of reasonableness exists if the lowest of three "truly comparable bids" was

chosen. If the low bidder is not chosen, if only one bid is submitted or the bids are not "truly comparable," the grantee has the burden to prove reasonableness of costs. See point C below for further information about noncompetitive negotiation.

3. Both price and the contractor's potential ability to meet specifications shall be considered.

4. Procurement of unnecessary or duplicative goods or services shall be avoided.

5. Small businesses and minority-owned businesses shall be considered.

6. Each grantee's or contractor's compliance with the terms of the grant or contract shall be

reviewed.

2. Procurement through solicitation of a proposal from only one source may be used only if at least one of the following conditions exist:

1 The contract is with an individual employer to provide OJT; 7. The grant or contract is for less than $500; 8. Competition is determined inadequate after solicitation of a number of sources (e.g., basic

skills training available via technical colleges who are also local job center partners); 9. The item or service required is unique; 10. Time is essential and only one known source can meet the need within the specified

timeframe; 11. Data are unavailable for competitive procurement; or 12. It is necessary that the needed items are manufactured by a certain source in order to be

compatible and interchangeable with existing equipment.

3. The WRI will make "purchase," "lease," or "lease-purchase" decisions for real and personal property based on the following factors:

1. cost reasonableness (may include net present and future value determination); 2. available alternatives; 3. terms and conditions of the "purchase," "lease," or "lease-purchase"; and 4. support (e.g., repairs, ongoing maintenance, training).

4. All purchase order files will be reviewed monthly by the Financial/Accounts Payable Specialist who will

follow up on item(s) which have not been received.

5. Vendors will be notified of tax exempt status of the WRI.




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6. Any variances from these procedures must be approved in writing by the Executive Director.

7. The Financial/Accounts Payable Specialist will retain copies of all supporting documentation (including the required bid information and proof of goods being ordered, received and paid for) in one location relative to all items on inventory.

2. Purchase Orders

1. A Purchase Order (Form 5) will be prepared in triplicate for all purchases totaling $50 or more, regardless of the individual unit cost, and those of a long-term nature (i.e., subscriptions, memberships). Purchases of equipment using limits prescribed under this procedure will be considered on a unit cost basis (see points e through i below).

2. Blank Purchase Orders and a log of used Purchase Orders will be maintained by the

Financial/Accounts Payable Specialist.

3. The originator of a purchase is responsible for completing the Purchase Order and securing the necessary signatures and bids/quotes prior to ordering the goods or services.

4. The Executive Director (or management staff positions listed in point f below for purchases of less

than $100) or designee must review and approve all Purchase Orders prior to ordering goods or services.

5. The appropriate staff person or designee oversees the purchase of related items shown hereafter;

and must review and sign Purchase Orders prior to submission to the Executive Director, as necessary:

Staff Person Type of Purchase

Office Manager Office, WRI/WDB/LEO meeting, legal notices or help-wanted

newspaper advertisements; cleaning or maintenance supplies (all offices); staff training; preprinted forms; office supplies; furniture and equipment for Central office (works with Regional Coordinators regarding purchasing field office furniture and equipment); and moving/installation of telephones and other equipment.

Workforce Resource Coordinators Field staff training; field staff reference materials; chamber or

other membership renewals; reordering printed forms or materials; participant recruitment newspaper advertisements; and equipment for field offices.

Chief Financial Officer FINANCE staff training; accounts payable checks; payroll

checks; W-2s; 1099s; audit services; and computerized accounting services. Computer-related purchases/repairs.

Regional Coordinator Summer Youth Program Discretionary Purchases (approval

limited to budgeted amounts and may exceed $100)

Page 3 of 5 Date Effective: March 1, 2003 Date Revised: February 1, 2012



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For non-administrative purchases of program nature (participant training, support, and assessments) and subcontract (including purchases of services agreements), see the corresponding guidelines in programs manuals and master plan.

6. Purchases of less than $100 may be made at the discretion of the Executive Director, Chief Financial

Officer, Regional Coordinator (or other designated Program Manager), and Office Manager without competitive quotations.

7. The Executive Director or designee must approve all purchases of $100 to $500 on the basis of three

(3) documented telephone quotations.

8. The Executive Director or designee must approve all purchases of over $500 on the basis of three (3) formal written quotations.

9. Purchase of any equipment item with a unit cost of $5,000 or more must be approved in writing by

approving funding source prior to purchase. Purchases of $5,000 or more not utilizing governmental funds, will be fully depreciated over the appropriate number of years, and charged back to governmental and non-government grants proportional to depreciation expenses or use allowance and in accordance with DWD administrative memorandums.

10. Approved Purchase Orders will be distributed as follows:

1. Original (top, first or white) - sent to vendor to authorize purchase. 2. Duplicate (middle, second or yellow) - filed in a pending Purchase Order file maintained by the

Financial/Accounts Payable Specialist in the Finance department. 3. Triplicate (bottom, third or pink) - retained by the originator of the Purchase Order or designee

until goods or services are received.

11. Disapproved Purchase Orders will be marked "disapproved" and returned with a written statement as to the reason for disapproval. Adjustments to Purchase Order amounts can be approved by the Executive Director or Chief Financial Officer.

3. Credit Card Purchases

1. Only one Elan credit card will exist for administrative purchases, issued in the name of the Executive Director, and is intended to be used to improve the efficiencies of the purchasing process, not circumvent the purchasing system. Purchases made by the Executive Director with credit cards meets Purchase Order requirement. Other credit cards will be allowed for local county-based job center and field office location to expedite purchases. Company-specific (example, Wal Mart) and workforce Resource office-specific credit cards are allowable with approval of Executive Director or designee.

2. Authorized user, will maintain physical control of the card, and is personally responsible for claims or

losses arising from misuse or unallowable charges. A lost or stolen card must be immediately reported to the credit card company by the Financial/Accounts Payable Specialist or designee.

3. Elan credit cards can be used for the following purchases, such as, out-of-town travel (including

airfare), workshop/seminar/other training costs, small equipment purchases (unit cost of less than $500), hotel/motel reservations or lodging, and meals. Purchase order procedures, approval signatures, and authorized rates must be followed as defined in Sections IV, V, VII though IX, and others as appropriate.

4. Monthly statements, related credit card slips, and signed purchase orders are delivered to the

Financial/Accounts Payable Specialist upon receipt.




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5. The Financial/Accounts Payable Specialist is responsible for reconciling purchase orders, credit card

slips, and monthly statements to prevent double payments and to assure completeness/accuracy of charges.

6. See credit card procedure summary located on web for current requirements and limits. 4. Routine and Repetitive Purchases

1. Routine and repetitive purchases occur on a recurring basis and include such items as: office supplies, forms and publication printing, newspaper subscriptions, chamber dues, and computer-related purchases. For such purchases vendors are identified and included on a pre-approved vendors list.

2. Offices supplies, printing, and service agreements are periodically bid with the successful bidder

holding the contract based on performance and continued favorable pricing. The Office Manager compares prices for office supplies and print jobs from various vendors, does a formal Request-for-Bid, when necessary, for office supplies and print jobs, and maintains the authorized vendor (s) list. The State of Wisconsin's Procurement Bulletin is consulted and meets the multiple bid requirement of the Financial Procedures Manual for office supplies, equipment (does not include computer-related equipment), and leases. All purchases of office equipment, leases, and service agreements must be approved by the Executive Director. The Executive Director designates authority to the Office Manager to sign office supply purchase orders of up to $500.

3. The Financial/Accounts Payable Specialist maintains a list of pre-approved chamber and other group

memberships, newspapers subscriptions, and related cost by WRI Office location. This listing is approved by the Executive Director and meets the purchase order requirement of the Financial Procedures Manual.

4. For computers and related purchases (modems, printers, service agreements, etc.) bids are solicited

from various vendors with the successful bidder holding the contract to provide. The Chief Information Officer or designee compares and documents prices for computers and related purchases from various vendors, periodically does a formal Request-for-Bid for same, as needed, and maintains the authorized vendor (s) or provider (s) list. A purchase can be made from the list or other vendor for the comparably same item at its lowest cost. The State of Wisconsin's Procurement Bulletin is consulted and meets the multiple bid requirement of the Financial Procedures Manual for computers and related purchases. All purchases of computers and related purchases and service agreements must be approved by the Executive Director or designee.

5. Receipt of Purchased Items

1. Upon receipt of goods and/or services, the person (the originator or designee) receiving the goods and/or services will indicate what item(s) purchased, in whole or in part, were received; sign and date the triplicate copy of the Purchase Order; and forward the Purchase Order with the packing slip or invoice attached to the Financial/Accounts Payable Specialist.

2. The Financial/Accounts Payable Specialist will compare the Purchase Order duplicate with the

triplicate, packing slip and invoice. If there are no discrepancies, the Purchase Order and invoice will be processed for payment. If a check was issued when the Purchase Order was originated, the duplicate P.O. and packing slip will be attached to the check copy.




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SECTION VI. PAYROLL General 1. Payroll checks will be mailed and payroll direct deposits delivered to Electronic Strategies, Inc. by the

Financial/Accounts Payable Specialist or designee. 2. Payroll checks will be issued biweekly. The Financial/Accounts Payable Specialist and/or the Chief Financial

Officer will be responsible for distributing payroll checks. 3. The Financial/Payroll Specialist will set up and maintain the payroll records and registers. 4. The Financial/Payroll Specialist will make all payroll deductions (i.e. taxes, insurance, retirement, child

support, IDS loan repayment, flexible benefits, etc.). 5. The Financial/Payroll Specialist will prepare all payroll tax and liability reports based on the payroll register. 6. Federal tax deposits will be direct-deposited (ACH system) at the bank (ESI) by the Financial/Payroll Specialist

or designee by 10:30 a.m., up to three business days before payroll checks are distributed. 7. The Chief Financial Officer or designee will review ORION Payroll edit report with time reports. Hiring 1. The Workforce Resource, Inc. and Local Elected Officials hire the Executive Director as stated in the

WRI/LEO Agreement. 2. The Executive Director must approve the hiring of all other employees except enrollees (participants or clients

approved by local case manager). 3. A Payroll Authorization will be completed by the Office Manager, employee's supervisor and/or the Executive

Director. 4. The Office Manager is responsible for training new staff employees about completing payroll time reports and

travel documents, and having them complete the following:

Form I-9 Form W-4, Employer Withholding Form Form WT4, New Employee Hiring Report Insurance Application Forms

The Office Manager will also have the new employee complete the Affirmative Action Form and Employee Data Sheet, as necessary.

5. An employee's hiring is not complete until the Payroll Authorization form, Form W-4, WT-4, I-9 and insurance

forms have been completed. 6. The Office Manager is responsible for review of Personnel Policies with new employee.

Following review of the aforementioned forms and policies, the new employee signs the New Employee Checklist and returns it to the Office Manager.




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7. All employees will comply with corporation personnel policies inclusive of prohibitions, restrictions and conduct.

8. The Executive Director or designee will set up a personnel file for all employees.

Time Reports 1. Each employee will be responsible for completing a time report (include travel) on a daily basis. 2. Completed time reports are reviewed and signed by the employee and supervisor and submitted to the

Financial/Payroll Specialist by Monday noon the week following the end of the payroll period. 3. Payroll checks will be issued biweekly with the pay day being the Friday following the end of the payroll period. 4. The Financial/Payroll Specialist will maintain a file of completed time reports and follow up to obtain missing

information. Participant Payroll 1. Participants shall be set up on the payroll system by the Financial/Payroll Specialist only after a participant has

been determined eligible by the assigned case manager. 2. All participants determined eligible will have a completed W-4, WT-4, I-9, Child Labor Permit (if necessary)

and Worksite Agreement submitted to the Financial/Payroll Specialist before being put on payroll. Enrollees who have been rehired may have some or all of these forms already completed and current.

3. Each participant will be assigned a payroll number, and a control sheet will be kept by the Financial/Payroll

Specialist on all numbers issued and to whom. 4. The hourly wage to be paid each participant will be verified on a Worksite Agreement filled out by the

appropriate field staff person. 5. For each participant, the appropriate cost category, program activity and funding source will be determined

and entered into the payroll computer by the Financial/Payroll Specialist. 6. Payroll hours will be transposed from each participant's time report or Payroll Summary form to the payroll

computer or input document. 7. All participant time reports must be signed by the appropriate supervisor and participant [electronic signatures

or evidence of approval is acceptable]. 8. All participant time reports must be reviewed for completeness and accuracy at the field office level and must

be signed/initialed by the assigned field staff person. 9. The Financial/Payroll Specialist will verify payroll calculations on at least a random basis. 10. Payroll checks must be distributed in a timely fashion. Exceptions to this requirement must be for legitimate

reasons (e.g., missing signature or paperwork) and approved by the Chief Financial Officer or Financial Services Coordinator.

11. The limits report (or replacement) from DWD is received periodically and is reviewed regarding participant

limitations on enrollment in program activities and total WIA participation.




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a. The appropriate WIMS-WIA report will be reviewed by the Financial/Payroll Specialist and appropriate filed staff.

b. Problems with participant enrollment limitations will be reported by the Financial/Payroll Specialist to

the Workforce Resource Coordinators and Regional Coordinators for follow up with appropriate field personnel.

12. The number of participant paid hours is checked by the assigned case manager to ensure the required

maximum is not exceeded. Staff Payroll 1. Staff shall be set up on the payroll system by the Financial/Payroll Specialist. Staff shall be set up on the

payroll system upon receipt of the Payroll Authorization filled out by the Office Manager, appropriate supervisor and signed by the Executive Director (completed W-4, WT-4, etc forms are also needed).

2. Staff shall be assigned a payroll number, and a control sheet will be kept by the Financial/Payroll Specialist of

all numbers issued and to whom. 3. Hourly wage rates to be paid will be verified on the Payroll Authorization filled out by the appropriate

department director and approved by the Executive Director. 4. The appropriate cost category, program activity, and funding source will be determined, built, and updated, as

necessary, in the payroll system by the Financial/Payroll Specialist. 5. Time reports will be turned in biweekly by all staff. Each time report will be signed by employee and his/her

supervisor or designee [electronic signatures or evidence of approval is acceptable]. 6. The Financial/Payroll Specialist will verify completeness an accuracy of payroll information. 7. The Financial/Payroll Specialist will input the appropriate payroll information into the payroll computer system

for the pay period. 8. Overtime will be paid if approval of the employee's supervisor and the Executive Director is secured in

advance of the time report's due date. 9. Sick and vacation time earned and taken will be entered into the payroll computer from the staff time reports.

For additional detail about sick and vacation time policies, see Personnel Policies. 10. Salary reduction form(s) will be completed by the affected employee and maintained in the FINANCE

Department by the Financial/Payroll Specialist.




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SECTION VII. TRAVEL General 1. Members of the Workforce Development Board, Workforce Resource, Inc. Board, the Local Elected Officials

and employees will be reimbursed for travel incurred in carrying out their duties and responsibilities. The rate of reimbursement for mileage, meals and lodging will be reviewed and determined by the Workforce Resource.

2. Local travel is defined as travel within the nine counties of Barron, Chippewa, Clark, Dunn, Eau Claire, Pepin,

Pierce, Polk, St. Croix, and adjacent counties. 3. Out-of-area travel is defined as travel outside the WDA or adjacent areas. 4. Staff/board travel will be logged on appropriate documents and maintained with staff timesheets, as

necessary, by Financial/Payroll Specialist or designee. The Financial/ Accounts Payable Specialist maintains travel not integrated with payroll documents.

Local Travel 1. Travel must be necessary for employees to carry out assigned duties and responsibilities. 2. Each employee will complete the travel voucher as part of time reporting system on a daily basis. 3. Mileage to and from the employee's residence will not be paid by the agency. 4. The cost of meals will only be reimbursed when an employee is traveling or working outside the WDA or when

meal is included as an approved part of meeting, workshop and/or training session. 5. The respective supervisor will review each travel voucher for verification of reasonableness of travel and

calculation of the amount of reimbursement. 6. The supervisor will approve/disapprove the travel voucher. Out-of-area Travel 1. All out-of-area travel must be approved in advance by the employee's supervisor. 2. Travel advances are permitted for out-of-area travel. 3. Receipts are required for lodging and common carrier transportation. Receipts must be attached to the travel

voucher. Travel Advances 1. Travel advances are allowed for out-of-area travel when anticipated costs will exceed $100. 2. If a travel advance is requested, the employee will complete a Travel Advance Request. The travel advance

must be approved by the Executive Director. 3. The Financial/Accounts Payable Specialist will record the advance in balance sheet account. 4. After the trip, the employee will enter the appropriate information on the travel voucher.

Page 1 of 2 Date Effective: July 1, 2008 Date Revised: July 1, 2008



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5. If the amount of the advance exceeds the amount on the travel voucher, then the difference will be immediately paid by the employee.

6. If the advance does not exceed the amount of the travel voucher, the difference between the advance and

total travel costs will be reimbursed to the employee. 7. If the advance should equal the travel cost, a travel voucher still must be submitted to document the costs.

REIMBURSEMENT RATES **

Mileage: } Breakfast: } Lunch: }effective rates (see rates on travel voucher) Dinner: } Lodging: } Parking: An allowable cost

* Maximum allowable tip is 15% and is included in the stated rate.

** Should travel be required in a high-cost area, as stipulated for DWD programs, the reimbursement

rate will be determined by the Executive Director. 8. See attached Administrative Policy/Procedure for additional detail.


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WEST CENTRAL WISCONSIN WORKFORCE RESOURCE

Office Procedures Manual TOPIC: Staff Travel and Related Administrative Policy and Procedure Workforce Resource, Inc. staff will be reimbursed for travel costs incurred while carrying out their official duties and responsibilities. The travel form (attached) includes the WRI Board-approved reimbursement rates and is used by staff, WRI and WDB Board, and LEO members. It is the intent of the travel policy to treat all positions equitably, without undue consideration to position and/or geographical location. Staff travel can occur two ways: Local and Out-of-Area. Local travel is defined as travel generally within the Workforce Development Area (WDA) encompassing the nine counties of Barron, Chippewa, Clark, Dunn, Eau Claire, Pepin, Pierce, Polk and St. Croix or in geographical areas adjacent to the WDA for training development (i.e., OJT, classroom training) and monitoring purposes. Out-of-area travel is defined as travel outside the WDA or its adjacent areas. Travel procedures differ when considering local or out-of-area trips. For example, time depart/return data elements must be completed for out-of-area travel when meal and lodging costs are to be reimbursed. The agency mileage reimbursement rate is $.485/mile and mileage is based on actual miles traveled for agency business. Meals and lodging for out-of-town travel are reimbursed at the rates shown on the travel expense log. Allowances for high-cost areas follow State-DWD guidelines. Travel Advances 1. Travel advances are allowed for out-of-area travel when the anticipated costs will exceed $100.00. Generally,

allow two weeks for processing of travel advances. 2. A travel advance is requested using the Request For Authorization of Non-Local Travel form. This form is

initiated by the affected employee and is required only when a travel advance is requested. 3. The Financial/Accounts Payable Specialist will record the advance in balance sheet account. 4. After the trip, the employee will complete the travel voucher and

a. if the amount of the advance exceeds the amount on the travel voucher, then the difference will be repaid immediately (within one week) by the employee, or

b. if the advance does not exceed the amount of the travel voucher, the difference between the advance and total travel costs will be reimbursed to the employee, or

c. if the advance should equal the travel cost, a travel voucher still must be submitted to document the costs.

IRS Requirements IRS regulations require employers to have "accountable" plans with specific requirements to avoid being in jeopardy of having legitimate, reimbursable expenses treated as income and reported on the W-2 form. These requirements include, but are not limited to, and reflect the WRI's continued intent to be in compliance with IRS requirements: 1. Travel expenses must be reported within 60 days of their occurrence. Generally, staff submit travel vouchers

(referred to in the regulations as "expense logs") within a two-week cycle. The travel vouchers "substantiate" the expenses, receipts are not required [under WRI policy receipts are required for lodging, parking, etc., but not meals].

2. If travel advances are given, they must be:

a. for business purposes, b. substantiated in writing, c. drawn within 30 days of use, and d. returned within 120 days (the unused portion).

3. Travel expenses can not be reimbursed for more than Federal per diem rates.

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Staff Travel and Related Administrative Policy and Procedure Page 2 Action Required

Local Travel 1. Travel must be necessary for employees to carry out assigned duties and responsibilities. 2. Each employee will complete the travel voucher as part of time reporting process on a daily basis. 3. Mileage to and from the employee's residence will not be paid by the agency. However, if an employee's first

or last stop of a work day is closer to her/his home (closer than to her/his office location), then mileage is reimbursable from or to her/his home, respectively.

4. The respective supervisor will:

a. review each travel voucher, b. verify reasonableness of travel and calculation of the amount of reimbursement, and c. approve/disapprove the travel voucher (signing the travel voucher denotes approval, remember to

date signature).

Out-of-area Travel 1. All out-of-area travel must be approved in advance by the employee's supervisor. 2. Travel advances are permitted for out-of-area travel. 3. Receipts are required for lodging and common carrier transportation. Receipts must be attached to the travel

voucher. 4. Receipts are not required for meals. The cost of meals will only be reimbursed when an employee is traveling

and/or working (must meet departure and return time requirements) outside the WDA and/or when the meal is included as approved part of the meeting, workshop, and/or training session. Departure/return time requirements are noted on "travel voucher" form.

General

Please put this policy and related forms in the office procedures manual.

WORKFORCE RESOURCE, INC. - WORKFORCE DEVELOPMENT BOARD, INC.


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SECTION VIII. WRI, WDB, AND LEO BOARD MEMBER EXPENSES 1. Members of the Workforce Resource, Inc. Board, Workforce Development Board, West Central County

Boards' Consortium will be reimbursed for their mileage and meal expenses incurred in carrying out their duties.

2. Board and Consortium members shall complete a travel voucher as outlined in Section VII. 3. The Executive Director shall verify and approve the travel voucher. 4. Checks will be prepared in accordance with Section IV-Cash Disbursements.




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SECTION IX. PROPERTY General 1. All equipment will be recorded in the general ledger by the Financial/Accounts Payable Specialist. An entry

must be made whenever property is disposed of by the Financial/Accounts Payable Specialist or Financial Services Coordinator. "Disposition" is defined as including inventoried items, with DWD reversionary rights, being transferred to other WIA entities within or outside our WDA, and other inventoried items no longer used and/or needed by the organization which is junked or donated (given) to another non-profit or public entity.

2. The Financial/Accounts Payable Specialist or Financial Services Coordinator will retain copies of all supporting

documentation (including the required bid information and proof of goods being ordered, received and paid for) in one location, relative to all items on inventory.

3. The inventory will be tracked by location including WRI offices and subcontractees, if any. Each county has at

least one inventory location (e.g., Clark-Neillsville). In two counties there are two locations each — Barron (Barron-Barron International Center; Barron-Rice lake) and Dunn (Dunn-Menomonie; Central-Menomonie). The River Falls office serves Pierce and St. Croix counties.

4. Each inventory item has an inventory sticker attached to it. The sticker number (and serial number) must be

included on transfer/disposition requests. If you cannot find a sticker number, the Financial/Accounts Payable Specialist or Financial Services Coordinator is contacted to find out if the item is on inventory and to get replacement sticker.

5. The following positions have responsibility for initiating transfer and disposition requests. The Initiator is

responsible for notifying Office Manager regarding availability of furniture or equipment if not needed in their respective areas.

Regional Coordinator (or other designated Program Manager) for WRI and/or WDB subcontractee Chief Financial Officer for FINANCE Department Workforce Resource Coordinators for field offices Office Manager for other Central transactions

Equipment versus Supplies 1. Supplies shall be defined as all items with a unit cost of $0 to $4999.99. WRI will inventory items having an

acquisition price of $500 or more and will reference these items as equipment procedure. 2. Equipment is defined as property having a useful life of more than one year and having a unit acquisition cost

of $5000 or more. 3. The Financial/Accounts Payable Specialist or Financial Services Coordinator will prepare a property record

form for all equipment and mark the item(s) with an identifying label. Physical Inventory 1. The Financial/Accounts Payable Specialist or Financial Services Coordinator will prepare a listing of all

inventoried item(s) from the property record forms. 2. The FINANCE Department will take a physical inventory of all inventoried items at least once each fiscal year

(may occur at different times depending on location), indicate on the listing the condition and location of the equipment, and ensure that all equipment is properly marked.

3. The Financial/Accounts Payable Specialist or Financial Services Coordinator will reconcile the physical

inventory with the balance sheet accounts and the prior year's inventory. A report on the inventory will be submitted to the Executive Director, operations committee of the WRI Board of Directors and the insurance agent, as necessary.




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Transfer, Loss, Damage or Destruction 1. The Office Manager will be immediately notified of all cases of transfer, loss, damage or destruction of any

inventoried item(s) using the Inventory Tracking form. 2. The Office Manager will assure that authorization in writing is given before any inventoried items are

transferred between agencies and/or offices. A signed receipt for the transferring items between agencies will be kept on file.

Transfer 1. To transfer equipment from one office to another, the initiator completes the Inventory Tracking form with all

information requested and submits it to the Office Manager for review and recommendation (approval, or disapproval with reason for non-approval).

2. Office Manager coordinates transfers between offices. 3. Office Manager approves all transfers of equipment, prior to transfer. 4. Financial/Accounts Payable Specialist or Financial Services Coordinator makes the appropriate inventory

record changes (completes lower left portion of form) and verifies inventory location, etc., by doing an on-site inspection once each year.

Disposition 1. Office Manager identifies if equipment is needed in another office. 2. If equipment is not needed, the Initiator completes the Inventory Tracking form with all information requested

and submits it to the Office Manager for approval. 3. Office Manager must approve all requests prior to disposition. If an inventoried piece of equipment, which has

DWD reversionary rights and is in an usable condition, is to be disposed of it must be offered to: a. WIA program operators (subcontractors) within the WDA (requirements may differ by funding source),

b. other WDAs in the state.

If the inventoried piece of equipment, which has DWD reversionary rights is not in an usable condition DWD will be notified and approve disposition.

4. The Office Manager uses the attached Available Inventory form to notify the above entities about available

equipment. If there are no interested parties, the equipment can be sold or otherwise disposed of (if original acquisition cost of $5,000 or more requires DWD approval- Office Manager will compose approval letter for Executive Director signature).

5. Financial/Accounts Payable Specialist or Financial Services Coordinator makes the appropriate inventory

changes on inventory tracking record and completes bottom portion of form. Purchase of Equipment 1. The purchase of all non-expendable personal property with a unit cost of greater than $5,000, in aggregate,

will be approved by appropriate funding source. Amounts may vary by each funding authority and shall take precedence.

2. If the total cost of leased equipment over a three-year period or less exceeds the purchase price, the

equipment should generally be purchased.




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3. The purchase of equipment will comply with the procedures in Section V-Purchasing and appropriate depreciation or use allowances will be used to charge various funding sources in an equitable manner.

Depreciation of equipment of $5,000 or more purchased with non-governmental funds 1. Purchases of $5,000 or more not utilizing governmental funds. 2. These purchases will be fully depreciated over the appropriate number of years using a straight-line

methodology. 3. These purchases will be charged back to governmental and non-government grants proportional to

depreciation expenses or use allowance and in accordance with DWD administrative memorandums. Disposal of Personal Property 1. Personal property will be disposed of and/or transferred within DWD or other funding source regulations (as

appropriate). 2. Title or ownership rights to equipment with an original unit acquisition cost of less than $5,000 purchased with

WIA funds or part of the CETA/JTPA transfer of personal property may be reassigned to a subcontractee or another office of the WRI or another WDB organization or disposed of after reasonable study and determination by the Office Manager and DWD approval. In absence of Office Manager the Chief Financial Officer or Financial Services Coordinator can make this determination.

3. Adequate records, as defined by the Chief Financial Officer or Financial Services Coordinator, will be kept

documenting the reassignment of title or ownership rights to the personal property. 4. Exception: In order to expedite transfers of computer equipment between offices of the West Central

Wisconsin WRI, the Office Manager or designee is authorized to complete the Inventory Tracking form, approve such transfers, and/or submit completed transfer forms to the Financial/Accounts Payable Specialist or Financial Services Coordinator without following the above procedure.




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SECTION X. LEASES 1. The Executive Director or designee will negotiate all leases. 2. The Executive Director will review and approve all leases. 3. Leases will correspond to program years whenever possible. 4. Copies of all leases will be immediately forwarded to the FINANCE Department where they will be kept on file.




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SECTION XI. INSURANCE 1. The Chief Financial Officer or designee will prepare and maintain an Insurance Register. 2. Insurance policies will be maintained in the files by the Chief Financial Officer or designee. 3. Insurance policies will correspond to the program year whenever possible. 4. Insurance policies will be carefully reviewed by the Chief Financial Officer before renewal. 5. Reasonably adequate coverage will be maintained for:

a. fire (building and/or contents), b. participant special health/risk, c. motor vehicle, d. other property, and e. liability insurance.

6. Audit exception insurance to meet DWD requirements, when available, will be maintained using non-WIA

funds.




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SECTION XII. TELEPHONES, PHOTOCOPY AND FAX MACHINES The general purpose of this section is to clarify company policy as it relates to program participant, general public, partner agency, and Workforce Resource, Inc. employee use of agency telephones, photocopy, and/or FAX machines. Within the IRS code employers, such as Workforce Resource, are allowed a small degree of flexibility regarding "small" benefits to employees excluded from income. These are "De Minimis" fringe benefits defined as "any property or service whose value is so small that accounting for it would be unreasonable or administratively impractical." (BNAs Payroll Administration Guide, 115:1107) Examples include, but are not limited to, '* ... occasional typing of personal letters or personal use of copy machines; * occasional parties and picnics for employees, coffee and doughnuts; ..." (BNAs Payroll Administration Guide,

115:1107) The WRI allows the occasional use of telephones, copy and FAX machines by Workforce Resource, Inc. employees as defined below. Members of the general public and other customers will be charged for use of telephones, copy and FAX machines, as appropriate. A fee schedule is shown below and may be updated by a separate document. Telephone 1. In general, personal long distance calls made by employees will not be charged to the agency. However, when

personal long distance calls are necessitated for business purposes (e.g., need to adjust private plans because of some work requirements) they are allowed. Other non-business related personal long distance calls should not be charged to the WRI, but when it does happen these telephone costs should be reimbursed by the employee. Workforce Resource, Inc. program participants are allowed to make telephone calls necessitated for program-related purposes and costs will be assigned by the cost allocation plan.

2. The detailed listings of credit card calls and other calls will be reviewed frequently by the Chief Financial

Officer and/or Financial/Accounts Payable Specialist and unusual calls will be investigated. 3. The detailed listings of other long distance calls from telephone companies will be reviewed by the office

Workforce Resource Coordinators, unusual calls investigated, and report back to Chief Financial Officer or designee.

4. General public and partner use of Workforce Resource, Inc. telephones will be billed separately utilizing the

agency invoice form and actual costs. In a case by case basis an alternate approach may be used, provided, at a minimum, the actual cost is retrieved (these arrangements are usually documented in a lease agreement, fee-for-service agreement, etc.). At most Workforce Resource, Inc. locations the actual costs of long distant and local telephone calls are billed directly by a telephone company for lines procured by partner agencies. Telephone cards may be used, on an incidental basis, by general public and partner agencies without additional charge for long-distance line access.

Photocopies and FAXES Occasional personal use of copy and FAX machines by employees is allowable if they provide paper and pay any long distance charges.

CHARGING FOR FAX/COPY MACHINE USAGE What follows are the guidelines for charging the general public and partner agencies for fax/copy machine usage in the Job Center. Workforce Resource, Inc. program participant photocopy and fax costs are charged to the non-administration cost pool and assigned based on the cost allocation system.




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The following charging standards are effective immediately:

GENERAL PUBLIC FAX AND COPY RATES: FAX: (local or long distance) $2.00 – First Page $1.00 – Following Pages PHOTOCOPY: $.10 per copy Money received should be placed in the Petty Cash Box and the transaction recorded on the Petty Cash Register. The Petty Cash Box should be maintained as outlined in the Financial Procedures Manual, Section III – Cash Receipt and Handling

PARTNER AGENCY FAX AND COPY RATES: FAX: (local or long distance) $.50 – First Page $.50 – Following Pages PHOTOCOPY: $.10 per copy (exception: $.05 for Job Service and other financial contributing partners with central approval) Money received should be placed in the Petty Cash Box and the transaction recorded on the Petty Cash Register. The Petty Cash Box should be maintained as outlined in the Financial Procedures Manual, Section III – Cash Receipt and Handling

BILLING PARTNER AGENCIES FOR FAX AND COPY USAGE: Maintain the Photocopy/Fax Log (attached) for those Partner Agencies who wish to be billed monthly. At the end of the month, tally the amount for each Agency separating the Fax charges and the Copy charges. If monthly charges are minimal billing periods can cover more than one month, but do not overlap fiscal years. Fill out the “Invoice” (attached) with the appropriate totals, clearly identifying office and person preparing the invoice, and submit to the Partner Agency for payment. (To set-up an Invoice numbering system, contact Financial/Accounts Payable Specialist.) Send a copy of the bill to the Finance Department for follow-up. NOTE: If Partner Agencies share copier costs (e.g., paper, toner, etc.) with Workforce Resource, the Finance Department will help establish the rate to be charged. Submit the Photocopy/Fax Log to the Finance Department for billing.




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SECTION XIII. CONSULTANTS 1. Consideration will be made of in-house capabilities to accomplish services before contracting for them. 2. The qualifications of the consultants and reasonableness of fees will be considered when hiring consultants. 3. Consultant services will be paid for as work is performed and invoiced. 4. The DWD and State WDAs will coordinate and conduct an RFP process for the financial audits. 5. WRI-WDB subrecipient audits, if any, are performed as part of their organization-wide audit. 6. The DWD will define and pay a reasonable portion of the audit costs as related to point 4 above.




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SECTION XIV. GRANTS AND CONTRACTS 1. Originals of all grants, contracts, and related correspondence/reports will be immediately forwarded to the

Chief Financial Officer for review and then forwarded to the Resource Development Manager or designee to do program fact sheet and filing.

2. Originals of all grants, contracts, and related correspondence/reports are maintained in the Central Office's fire

proof file cabinet by the Resource Development Manager or designee. Electronic copies of contracts and related documents will also be maintained on the computer network and will be included with off-site backup.

3. Subgrantee, if any, agreements and related correspondence/reports maintained in Central's fire proof file

cabinet by the Regional Coordinator (or other designated Program Manager). 4. The Chief Financial Officer or designee will review financial budgets and prepare a budget journal entry to

record each award on the general ledger. 5. The Regional Coordinator (or other designated Program Manager) and Chief Financial Officer will carefully

review each award to ensure that all financial provisions will be complied with. 6. The Regional Coordinator (or other designated Program Manager) will carefully review each award to ensure

that all programmatic provisions will be complied with.




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SECTION XV. BUDGETS 1. Financial budgets will be prepared by the Executive Director, Chief Financial Officer, Regional Coordinators,

and other staff, as appropriate. 2. The Chief Financial Officer will ensure that budgets, if available, are on file for all grants and contracts. 3. Changes to subcontractor, if any, budgets will be submitted to the Chief Financial Officer as soon as they are

known. 4. Composite (e.g. operations, programmatic) and detail budgets will be approved by the WDB, WRI and the

LEOs per the WRI/WDB/LEO Agreements.




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SECTION XVI. BOOKS OF ORIGINAL ENTRY 1. The agency will utilize a double entry system of accounting for all funds. Accounting records will be

maintained with the ORION financial system as required by the DWD, other funding sources, the WRI Board of Directors and management.

2. All necessary and required cash receipts, cash disbursements and necessary journal entries will be

maintained on the ORION financial system, Sentry File, or subsidiary records. 3. Adequate documentation will be maintained to support all general journal entries. Journal entry adjustments

will require at least two Finance Staff involved in the preparation, approval, and/or entry to appropriateness of the transaction and adequacy of documentation.

4. The Chief Financial Officer or Financial Services Coordinator will review the reports generated by ORION or

using ORION information each month. 5. The Chief Financial Officer or designee will review and approve all journal entries prior to entry into ORION

Financial system. The Executive Director will review and approve selected journal entries prepared by the Chief Financial Officer.




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SECTION XVII. REPORTS 1. The WRI Finance Department staff will produce the monthly reports from data maintained on the ORION

financial system. Electronic copies of ORION and other reports are kept beyond each month. 2. The monthly financial reports produced by WRI FINANCE Department staff and the ORION financial system

are to meet all requirements established by the DWD and other funding sources (e.g., W2/FSET, etc.). 3. General Ledger transactions must be retained for retrieval purposes to meet Federal and State requirements. 4. The Consolidated Balance Sheet and/or Trial Balance will be processed at the end of each month. Asset,

liability and fund accounts are listed in their respective sections on the report. 5. Accounts Payable and Payroll distribution reports will be processed as necessary. 6. An active grant-specific revenue and expense statement will list composite revenue and cost category (or

objective) expense totals. 7. The General Journal will list all journal entry transactions for the accounting period (month, funding period,

etc.) and will be printed as necessary. 8. An account analysis report will be generated, as necessary, and list detail transactions for the entire year in

the desired account number sequence. 9. Financial reports will be reviewed by the Board of Directors. 10. All subrecipients, if any, must submit an end-of-month expenditure report within the prescribed timeframe. 11. All subrecipients, if any, will submit other reports as needed by the Chief Financial Officer and Regional

Coordinator (or other designated Regional Coordinator (or other designated Program Manager)).




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SECTION XVIII. MATCHING FUNDS, NONFEDERAL IN-KIND CONTRIBUTIONS, AND STAND-IN COSTS Federal legislation requires matching funds (cash and/or in-kind) for several programs funded, at least partially, with federal dollars. Federal In-kind contributions are goods and/or services that benefit the affected program and must be paid for with state or local, private or public funds; and cannot be Federal money (e.g., grant money) or Federally-funded goods/services received directly or indirectly (e.g., received via a State or other organization). Federal funds can not match Federal funds. Cash match is received from a variety of sources and follow many of the rules for in-kind contributions. Such funds are intended to expand the benefits of the affected program for an identified participant base and/or to expand the program to a larger participant group. Cash match sources can include State and local public resources, private entities, such as, foundations, employer cash contributions/donation/fees, and individuals. How do we get In-Kind Match? 1. Sources of matching fund contributions varies by funding source regulations can include, but are not limited to:

a. State and local share of classroom training expenses, b. An allowance for use of employer equipment during training period, c. Use charges for meeting rooms donated for orientations. motivation training sessions, etc., d. Other sources (e.g., participant wage during OJT period; supervision related charges), and e. Allowable unemployment insurance contributions (not to exceed 50% of the total match requirement

for selected programs),

These are examples of sources WRI has used to meet match requirements for various grants, and do not directly relate to all funding authorities. For WIA and other funding authority programs, see the DWD WIA Policy and Procedures Manual.

2. For various programs, the state and local share of classroom training expenses was the most fruitful source

used, in early years, to meet the match requirements. [The classroom training match easily met the two percent requirement for JOBS.] For affected WIA dislocated worker programs, unemployment insurance contributions was a significant source of match.

How can programs capture related classroom training match? Local technical colleges generate the match information. The classroom training match is based on the number of credits, the related department, and a set rate per credit. Generally, the state/local share of business classes is at a higher rate then, let's say, a general/liberal arts class. The local technical college needs to be contacted in writing to request this match information. The technical college needs to know the number of credits by department/school to generate a response regarding match. WRI field staff compile a list of participant names and social security numbers, associated class names, and course number by technical college (part of the course number identifies department/school). WRI Finance Department representative reviews list received from field office, identifies related tuition paid by source of funds and sends list to appropriate technical college and contact person (WITC and CVTC are the two institutions we get match from).




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After the letter is sent, it usually takes two to three weeks to get the match information. There have been two forms in which the match is received. If the match information received includes both Federal and State/local shares the Federal funded amounts are deducted. General Procedure 1. The appropriate match documentation is gathered by the WRI Finance Department using the special reports

defined above and/or Forms 23 and 23B (see the attached Form 23B for additional process-related information). Forms used can vary by funding source.

2. The Chief Financial Officer or Financial Services Coordinator, or designee, will receive the contribution

information and will prepare, sign, date, and mail the contributions report, as necessary to the appropriate funding authority in a timely manner.

3. Contribution reports will be reviewed by the Executive Director, as necessary. 4. A summary of all non-Federal contributions and supporting documentation will be maintained by the Chief

Financial Officer or Financial Services Coordinator, or designee. Stand-in costs (see WIA regulations) means costs paid from non-Federal sources which a recipient proposes to substitute for Federal costs which have been disallowed as a result of an audit or other review. In order to be considered as valid substitutions, the costs (1) must have been reported by the grantee as uncharged program costs under the same title and in the same year in which the disallowed costs were incurred and (2) must have been incurred in compliance with laws, regulations, and contractual provisions governing JTPA. 1. Stand-in costs shall be from the same title, cost category, and funding period as the costs which they are

proposed to replace. 2. Stand-in costs must also be traceable in the recipient's or subrecipient's financial system. 3. Stand-in costs for the WRI include

a. Subcontracted activities, and b. classroom training expenditures, to the extent allowed by DWD, paid for by technical colleges with

local revenue to cover costs of education over and above those covered by tuition payment made by WRI.

4. Stand-in costs will be reported by subcontracts as required by the WRI. Stand-in costs will be obtained from

technical colleges relative to tuition paid by WIA AND OTHER FUNDING AUTHORITIES for local share of classroom training expenses.

5. A summary of all stand-in costs (and supporting documentation) will be maintained on the general ledger by

the Chief Financial Officer or Financial Services Coordinator, or designee.




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SECTION XIX. COST ALLOCATION PLAN 1. Workforce Resource, Inc. Cost Allocation Plan (attached) details the methods by which costs are assigned to

the funding sources (WIA and non-WIA) and cost classifications within each funding source (program activities, Direct Training, Retraining Services, Core and Intensive Services, Needs Related Payments, Supportive Services, Training-Related and Supportive Services, Work Activities, Administration, etc.), as specified by funding sources.

2. The Cost Allocation Plan will be periodically reviewed and updated as necessary by the Chief Financial Officer

or Financial Services Coordinator.




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SECTION XX. OTHER Minutes of Meetings 1. Accurate minutes of all meetings of the Board of Directors and Committees will be maintained by the staff

liaison to the committee, Office Manager or designee. 2. The Office Manager or designee will prepare accurate minutes of Board of Director meetings. 3. The Executive Director will prepare accurate minutes of operations committee meetings. 4. The Regional Coordinators or other staff will prepare accurate minutes for the assigned committee. 5. The Regional Coordinators, Employer Relations Managers, Chief Financial Officer and Executive Director will

receive and review minutes of all meetings of the Board of Directors and Committees. 6. The Chief Financial Officer will note all items in the minutes relating to Finance and take appropriate action. Grants/Accounts Receivable 1. Documentation will be maintained for grants/accounts receivable. 2. Grants/accounts receivable will be recorded in the books and collected on a timely basis. Financial Procedures 1. The Chief Financial Officer will prepare and maintain on a current basis job descriptions for the Finance

Department summarizing key financial activities. 2. Financial procedures will be reviewed at least annually with the Oversight Committee of the Board and Chief

Financial Officer and updated as necessary. 3. Changes to the financial procedures manual will be approved by the Executive Director prior to

implementation. Record Retention 1. Records (electronic copies are kept using Sentry File as established in consultation with the State DWD acting

on behalf of the DOL) will be maintained subject to Federal, State, and local requirements. Certain records will be kept permanently, such as, audit reports, canceled checks for important payments, legal and other important correspondence, current contracts and leases, end-of-year financial statements (journals, ledgers, trial balances, etc.), tax returns, real estate property records (appraisals, mortgages, bills of sale, deeds, depreciation), minutes and other corporate records (by-laws, articles of incorporation, trade mark/name registrations).

2. The DWD record retention requirements for WIA programs as defined in the "Program Procedure Manual"

and related documents will be followed: a. Participant, Complaint/Appeal, and other pertinent records to the DWD contract will be maintained for

three years (plus additional time beyond three years until any applicable litigation, audit findings or claims have been resolved).

b. Records of non-expendable personal property acquired with DWD funds will be maintained until three years after disposition (plus additional time beyond three years until any applicable litigation, audit findings or claims have been resolved).

c. WIA participant records need to be maintained for seven years beyond program exit. 3. Internal Revenue Service (IRS) record retention requirements, generally seven years, will be followed relative

to payroll documentation, expired contracts and leases, etc. W-2 requirements follow a minimum fifteen-year rule and may vary by local office.




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SECTION XXI. COMPUTER CONTROLS AND SECURITY 1. The WRI ORION financial system controls and security will use a combination of network and ORION

software safeguards, including passwords and restricted access by user and/or work station. 2. WRI employees will have access to the ORION financial system on a need-to-know basis. 3. WRI management staff will have access, at a minimum (varies by position), to ORION financial system reports

and report generating features. 4. Password and other network security measures and ORION level passwords will be maintained by the system

manager(s). 5. Program diskettes are copied with the original program diskettes secured off premises, as necessary. 6. Periodic backup of financial system and information will be done for each location using an offsite computer

system data backup service company on a periodic basis. 7. The Finance Department computer rooms are to be locked whenever the WRI staff members are not in the

building. 8. The Chief Financial Officer and Financial Staff will have access to the TESSA financial modules. 9. The Executive Director and designees, Chief Financial Officer and/or Financial Services Coordinator, Regional

Coordinators, Workforce Resource Coordinators, Financial Specialists, Resource Specialists, and assigned case managers will have access to the ASSET, TESSA and CARES reporting system, as appropriate.




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SECTION XXII. AUDIT 1. The West Central WDA Grant Recipient and Administrative Entity (WRI) will have an A-133 audit for fiscal

years ending June 30, 1991 and after. Audits will be conducted in compliance with Government Auditing Standards and Provider Agency Audit Guide endorsed by DWD (note also State Single Audit Guidelines issued by DOA), SAS, yellow book, and other regulatory requirements.

WRI Board will provide oversite to the audit procurement and selection process. WRI Board chair or

committee (WRI Board or committee) will actively participate with audit process and auditors.

WDAs will procure the services of an independent auditing organization through a competitive RFP process. The contract with the successful auditing organization is the responsibility of the WDA. The cost of the audit will be the responsibility of the WDA. The WRI shall submit one copy of the final audit report to DWD and other funding authorities within six (6) to nine (9) months of fiscal year end depending on funding source requirement.

2. Subrecipients of WIA and other funds from the WRI are required to have these funds audited annually, as

defined below, and to submit a copy of the resultant audit report, upon receipt, to the WRI. a. The subrecipient shall have a single, organization-wide audit performed by a qualified independent

auditor as required by federal and state law and regulations. b. The audit shall be performed in accordance with Government Auditing Standards and federal Office of

Management and Budget (OMB) Circular A-133 and state single audit guidelines issued by the Wisconsin Department of Administration (DOA).

c. The audit under A-133 must be completed and submitted within six (6) to nine (9) months of the subrecipients fiscal year end. Audits received by the WCW WRI must be resolved within six (6) months of receipt.

Audit Resolution 1. The Chief Financial Officer or Financial Services Coordinator will maintain a log of each audit report received

from subrecipients, if any, recording: a. Subrecipient name, address, and contact person b. Grant number, type of agreement (or program operated) and dollar value of contract c. Name of CPA firm d. Date report received e. Questioned costs and/or administrative deficiencies noted, if any

The Chief Financial Officer or designee will do the subgrantee audit report review and confer with the subrecipient to obtain responses to identified findings. The Chief Financial Officer will coordinate activities with the State cognizant agency.

2. Within ten (10) days of receiving the subrecipient audit report, the Chief Financial Officer or designee will send

a letter to subrecipient requesting a written response, within 30 days, to differences between audit and dollar value of contract/agreement, any questioned costs, and/or administrative deficiencies noted in report.

A copy of the subrecipient's audit report and related correspondence will be forwarded to the WDA's auditing organization and DWD, as necessary.

3. WRI staff (initiated by the Chief Financial Officer) will review the subrecipient's response and determine

adequacy. If the subrecipient accepts the findings as identified in the letter referenced in point 2, the subrecipient shall make necessary administrative adjustments and/or send a refund check payable to the Workforce Resource. If the subrecipient fails to send the refund due, the WRI will begin debt collection proceedings in accordance with funding source regulations and the procedure defined below.




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4. If the subrecipient disagrees with any part or parts of the letter referenced in point 2, the subrecipient may make a formal appeal to the WRI within ten (10) days of receipt.

5. The Chief Financial Officer will send letter to subrecipient acknowledging completion of audit work for the

affected period upon final determination and resolution of the audit. Submission of Audits 1. Copies of the WCW WRI audit report shall be submitted in accordance with reporting standards for financial

audits contained in the Government Auditing Standards. 2. Subrecipient auditors shall submit copies to grantors that provided awards of federal funds. 3. Audit reports are due within 30 days after the completion of the audit, but the audit should be completed and

the report submitted not later than nine (9) months after the end of the recipient's fiscal year unless a longer period is agreed to with cognizant or oversight agency.

4. In addition, recipients of more than $300,000 in Federal funds shall submit, at a minimum, one copy of Form

SF-SAC within 30 days after issuance to the central clearinghouse for nonprofit audits at the following address:

National Clearinghouse For Federal Audit Reports U.S. Department of Commerce 1201 East 10th Street Jefersonville, IN 47132

Debt Collection 1. When an audit determines that the subrecipient has expended funds which are questioned, the subrecipient

shall be notified (within seven days of receiving draft audit report) and given the opportunity (written response due back to the WRI within 30 days of notifying subrecipient) to justify questioned expenditures prior to the WCW WRI and DWD's final determination of disallowed costs, in accordance with procedures established under WIA.

2. A debt is established when costs are disallowed in writing by one of the following:

a. Audit. An audit resolution findings and determinations letter;

b. Ruling. A complaint and appeal ruling;

c. Report. A report of an investigation;

d. Closeout. A grant closeout report; or

e. Monitoring. A monitoring report.

3. Collection options available to the WRI include but are not limited to the following: a. requiring cash payment; or b. other legitimate options to offset the debt.

4. In accordance with legislation and regulations, nothing shall prevent the following:

a. The WRI charging the subrecipient interest, at a competitive rate determined in consultation with DWD (such as, the current prime rate recognized by the WRI's bank of record), on the debt within thirty days of being established; or

b. The WRI imposing other sanctions on the subrecipient.




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5. The WRI will seek another legal remedy only after two letters have been sent to the subrecipient requesting immediate acknowledgement of the debt and repayment. Each letter will allow the subrecipient ten (10) working days to respond.




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SECTION XXIII. PROGRAM INCOME 1. All WIA-related program income will reported to the DWD at least once each year as part of the affected

specific WIA Title or program closeout/settlement process and can be used for program purposes. Other funding source requirements will be consulted and used as necessary.

2. Subcontractees will report program income to the WRI as part of the closeout package for each grant

agreement. 3. WIA-related funds, including program income, must also be traceable in the recipient's or subrecipient's

financial system. 4. The WRI shall disburse program income, rebates, refunds, contract settlements, audit recoveries, and interest

earned on such funds before requesting additional cash payments. 5. WIA procurements shall not permit excess program income (for nonprofit and governmental entities) or

excess profit (for private for-profit entities). If profit or program income is included in the price, the awarding agency shall negotiate profit or program income as a separate element of the price for each contract in which there is no price competition and in all cases where cost analysis is performed. To establish a fair and reasonable profit or program income, consideration shall be given to: a. The complexity of the work to be performed; b. The risk borne by the contractor; c. The contractor's investment; d. The amount of subcontracting; e. The quality of the contractor's record of past performance; f. Industry profit rates in the surrounding geographical area for similar work; and g. Market conditions in the surrounding geographical area.

6. Program income means income received by the recipient or subrecipient directly generated by a grant or

subgrant supported activity, or earned only as a result of the grant or subgrant. Program income includes: a. Income from fees for services performed and from conferences; b. Income from the use or rental of real or personal property acquired with grant or subgrant funds; c. Income from the sale of commodities or items fabricated under a grant or subgrant; d. Revenues earned by a governmental or private non-profit service provider under either a fixed-price or

reimbursable award that are in excess of the actual costs incurred in providing the services; and e. Except for States, as defined in the Department of Treasury's Cash Management Improvement Act

regulation at 31 CFR 205.3, interest income earned on advances of subgrant funds.

Program income does not include: a. Rebates, credits, discounts, refunds, etc., or interest earned on any of them, which shall be credited in

accordance with WIA, Cost principles and allowable costs; b. Taxes, special assessments, levies, fines, and other such governmental revenues raised by a

recipient or subrecipient; or c. Income from royalties and license fees for copyrighted material, patents, patent applications,

trademarks, and inventions developed by a recipient or subrecipient. 7. WRI may retain any program income earned only if such income is added to the funds committed to the

particular WIA grant or subgrant under which it was earned and such income is used for WIA purposes and under the terms and conditions applicable to the use of the grant funds. The classification of costs and the administrative cost limitation of WIA shall apply to such funds.




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8. Costs incidental to the generation of program income may be deducted, if not already charged to the WIA grant, from gross income to determine program income.

9. Program income generated under title II may also be used to satisfy the matching requirement of the WIA, as

appropriate. 10. Program income shall be used prior to the submission of the WIA final report for the funding period of the

program year to which the earnings are attributable. 11. If the subgrantee that earned program income cannot use such income for WIA purposes, the WRI may

permit another entity to use the program income for WIA purposes. 12. Program income not used in accordance with the requirements of this section shall be returned to the DWD. 13. Rental income and user fees on real and personal property acquired with WIA funds shall continue to be WIA

program income in subsequent funding periods. There are no Federal requirements governing the disposition of all other income that is earned after the end of the funding period.


financial procedures manual - workforceresource.org

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