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4.4 Cash Management and Invoicing Standards



4.4 Cash Management and Invoicing Standards

Effective Date: TBD

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/SitePages/Guidance.aspx?web=1
  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
  8. INVOICING STANDARDS

    Cash is requested on a per grant basis, and local WDBs are required to use the Purchase Order Number assigned to the Grant to request cash. Cash drawdowns must be made as close as possible to the time of making disbursements.9

    To request cash, a local WDB must complete the WIOA Request for Payment Invoice Form. The completed form must be emailed to Einvoice@dwd.wisconsin.gov.

    Invoices are typically processed within 2-3 business days after being received. Any invoices received after 10am will be considered as next day receipt.