Federal regulations, at 45 C.F.R. 92.20, require grantees to monitor cash draws by their subgrantees to "assure that they conform substantially to the same standards of timing and amount as apply to advances to the grantees." In accordance with the federal requirement that grantees must limit the amount of funds drawn down to the minimum required to meet actual and immediate cash needs, ODJFS established case management and reporting standards for county family services agencies and local WIA areas in the following OAC rules:

ODJFS Office of Fiscal and Monitoring Services (OFMS) monitors compliance with these standards and provides technical assistance to assist agencies/areas in improving their cash management and reporting practices.

Effective immediately, ODJFS fiscal supervisors may schedule an on-site visit for any agency with excess cash on hand and will review the following in more detail:

• Any documentation sent per the financing and cash management rule for the applicable agency explaining circumstances for non-compliance;
• The status of any funds transfers made in current and prior years;
• The existence of any ceiling excess;
• A comparison of non-reimbursable expenditures reported versus non-reimbursable receipts reported; and
• Any past annual reconciliation results and any patterns of under-reporting of expenditures or of a negative or excess cash balance, including any outstanding debt due ODJFS.

After review of the factors listed above, ODJFS will notify those counties that are over-advanced/under-reported, and request documentation of the steps that will be implemented to correct the identified issues, and ensure future compliance. The documentation shall include the following:

• Reason for excess cash on hand;
• Steps the agency will take to resolve the issue;
• Steps that will be taken to avoid a reoccurrence in the future; and
• Timeframes for resolution of all issues, including a statement and timeframe regarding when expenditures will be reported for cash drawn to date.

ODJFS fiscal supervisors will review all proposed documentation, and will work with the agencies to reach a mutually acceptable resolution of all issues.

In addition to the above actions, the OFMS Monitoring Services Division may conduct additional monitoring of the agency, including an in-depth analysis of the agency's cash management practices and current cash position.

If a county agency or local area fails to fully implement the agreed upon compliance plan or, if, as a result of the financial review or monitoring processes, ODJFS determines the agency or area is financially or administratively challenged, ODJFS may, in accordance with 45 C.F.R. 92.12 or 29 C.F.R. 97.12, designate the agency or area as a high risk subgrantee. In such instances, the OFMS Deputy Director may implement any of the special conditions specified in 45 C.F.R. 92.12, 29 C.F.R. 97.12, and O.R.C. 5101.24 and outlined in FAPL No. 16, ODJFS Subrecipient Monitoring and Risk Assessment, including approval of a temporary withholding of requested draws for additional funds. If a temporary hold is implemented in accordance with O.R.C. 5101.244, OFMS will notify the county agency or area of the action in writing. Copies of the notification will be sent to the county director, county auditor, and county commissioners.

The temporary hold may remain in place until the agency or area complies with Ohio Administrative Code rules governing cash management and reporting practices by reporting expenditures, sufficient to justify the amount of cash drawn in the current fiscal year, into the County Finance Information System (CFIS). Notwithstanding the foregoing, the hold may continue at the discretion of the OFMS Deputy Director until such time as the agency or area is no longer considered to be in high risk status.

For additional questions please contact your ODJFS Fiscal Supervisor or call the Bureau of County Finance and Technical Assistance at (614) 752-9194.