4.4 Cash Management and Invoicing Standards

4.4.1 Cash Management and Invoicing Standards

Effective Date: August 1, 2024

Background

There is a strong emphasis in Uniform Guidance on having a cash management system in place to accurately track the receipt, disbursement and recording of funds between the awarding agency and grant recipient.¹ This policy specifies the minimum requirements for cash management and provides guidelines for the reimbursement of Workforce Innovation and Opportunity Act (WIOA) funds from the Department of Workforce Development (DWD).

Cash Management

The local Workforce Development Board (WDB) must have a written cash management policy and/or procedures that minimally address the following:

1. Adequate internal controls² to safeguard cash and cash equivalent assets.³
   1. Cash equivalent assets include, but are not limited to:
      1. ATM PINs & PINs to checking accounts
      2. Passwords to sensitive accounts
      3. Credit Cards and/or Gas Cards
      4. Debit Cards
      5. Purchase Cards
      6. Blank check stock
      7. Check-signing machines
      8. Bus tokens and passes
      9. Gift Cards
   2. For more information regarding internal controls, please visit: https://www.coso.org/guidance-on-ic
2. Recovering improper payments. The costs incurred by a non-Federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate.⁴
   1. Improper payments⁵ include but are not limited to:
      1. Over-payments to subawards and contractors
      2. Disallowed costs
      3. Participant payments erroneously awarded
      4. Uncollected tuition refunds
      5. Double payments
      6. Payments paid at the wrong rate
      7. Unauthorized charges on fees and penalties paid in error
      8. Overpayments on blanket P.O.s
3. Cash Forecasting Method. Mechanism or tool used by the local WDB to determine the amount of cash to draw.
4. Payment of non-sufficient funds, overdraft fees, and other penalties which cannot be paid using Federal Funds.⁶
5. Reconciliation. Reconciliation must be performed between the cash drawdowns and the expenditures on an individual grant basis, monthly. Local WDBs must separately account for receipt, obligation, and expenditure of funds by award or fund source.
6. Authorized individuals and separation of duties. Sufficient internal controls must be in place to ensure proper segregation of duties for the following functions: recording, custodian, authorizing, and reconciliation of funds.⁷
7. Accounting Records. Records relevant to drawdowns and supporting documentation must be retained by the WDB or the WDB's fiscal agent.⁸

Invoicing Standards

Cash requests are to be made on a per Purchase Order (PO) number basis. An invoice may reference more than one PO number if there is a need to correct a prior invoice payment for an open PO. The total invoice amount must be equal to or greater than $0.00. Emphasis must be placed on minimizing the time between the transfer of funds from DWD-DET and the disbursement of funds to pay allowable costs.⁹

To request cash, a supplier must complete the Supplier Request for Payment Invoice Form and supply documentation to substantiate their cash drawdown request. This documentation must reconcile with the total amount of cash being requested, and may include, but is not limited to the following:

1. Accounting records such as general ledger, trial balance, and/or payroll ledger.
2. Accrued expenditure documentation detailing the following:
   1. Wages and salaries earned but not paid
   2. Invoices received but not paid
   3. Subrecipient accrued expenditure reports received but not paid
   4. Payments earned on an OJT contract as of the end of a month but not yet due or paid to the employer)

All documentation must be emailed to DWDDETInvoicing@dwd.wisconsin.gov.

The following may result in delayed payment:

1. Incomplete and/or inaccurate cash requests, including, but not limited to, requests lacking sufficient documentation and/or requests where the documentation provided does not reconcile with the total amount of cash requested.
2. Late submissions of required Financial Status Reports (FSRs) for two or more consecutive months.
3. Conditions of persistent non-compliance.

Invoices are typically processed by DWD Accounts Payable within 2-3 business days of approval by DWD-DET.

• ¹ 2 CFR § 200.302
• ² 2 CFR § 200.1 “Internal controls”
• ³ 2 CFR § 200.303(a)
• ⁴ 2 CFR § 200.428
• ⁵ 2 CFR § 200.1 “Improper payment”
• ⁶ 2 CFR § 200.441
• ⁷ 2 CFR § 200.303
• ⁸ 2 CFR § 200.302(b)
• ⁹ 2 CFR § 200.305(b)