Compliance
We conduct these reviews to ensure that funds are being managed in compliance with OMB CFR 200, and appropriate program procedures for SNAP E&T are being followed as per USDA, Food and Nutrition Service, as required.
Prior to the review, LISC will send a letter explaining the process and requesting a number of documents for pre-review that must be submitted by a designated date. Reviews take about three hours, sometimes less. Finance and program staffs are required to participate.
The following documentation will be reviewed in detail during the on-site visit. If warranted, additional documentation may be requested.
- Invoices, cancelled checks, bank statements for each non-personnel charge on financial reports for the month(s) being reviewed
- Payroll register and time & effort reports
- Fringe invoices with cancelled checks/bank statement
- General Ledger review for SNAP E&T charges
- Procurement files for any consultants
- 3 participant files (minimum) including assessment documentation
- Attendance records
- Student Policies & Procedures
The Following are Common Compliance Issues Identified During a Review:
Issue: Incorrect Time Sheets
Time sheets, also called time and effort reports, are required to support the salary/fringe costs charged to federal grants.
Time sheets must:
- Reflect the time (hours) spent on SNAP E&T (the funding source) each day
- Coincide with pay periods
- Be signed by the employee and supervisor
Issue: Procurement Process
This process must be used for consultants or any other instance that requires a contract using government funds.
Documentation Required:
- RFP or RFQ issued to a minimum of 3 persons/companies with an effort to solicit Minority / Women Business Enterprises (MBE/WBE)
- All responses to be retained on file
- Selection criteria documented
- Interview notes, copies of emails or notes from phone calls – include dates, times, and persons involved
- sam.gov checked, printed and in file prior to signing of contract
- Final selection with rationale, and acceptance (Signed Contract)
Issue: Missing or Incomplete Payment Information
- All expenses charged to a federal grant must have payment information on file
- During the compliance visit, LISC will review backup for all invoiced expenses
- Canceled checks or credit card statement and bank statement showing credit card was paid
Issue: Updating Internal Policy and Procedures Reviews
- Personnel and Finance/Accounting Policies & Procedures/Procurement Policies should be reviewed/updated at least every 2-3 years
- If no changes are required, re-issue document with the notation “Reviewed by Board of Directors mm/dd/yyyy”