HomeMy WebLinkAboutRESOLUTIONS - 07132023 - 2023/499
ATTACHMENTS
Number: 200.8
Date: 5-27-10
Section: Budget & Fiscal
CONTRA COST A COUNTY
Office of the County Administrator
ADMINISTRATIVE BULLETIN
SUBJECT: Capital Asset Accounting and Budgeting Policy
The County policy for capital asset accounting and budgeting must conform to State definitions and
regulations as set forth in the manual of Accounting Procedures for Counties and reflect current
values. This policy establishes the basis for financial classification and does not affect the program of
physical inventory control and accountability.
Capital assets are assets of significant value having a utility that extends beyond the current year. An
improvement is a replacement of a component part of a capital asset by an improved or superior part,
an addition of new parts, or an alteration or a structural change to a capital asset that results in a
functional improvement over its original state that materially adds to the value of the asset or
appreciably extends its life.
Land improvements enhance the value of the land itself (such as grading, filling, and sloping or
ditching for drainage) and are charged to the land account. Ground improvements add other items to
the basic land and are charged to the Buildings and Improvements fixed asset category. Examples of
grounds improvements are lawns, trees and shrubs, sprinkler systems, fences and walls, and paving.
The following capital assets are to be capitalized and individually budgeted and controlled:
I Land. All land acquisitions and land improvements, without regard to cost.
II Structures and Improvements.
a Permanent stnrctures costing $100,000 or more.
b Additions, structural betterments and ground improvements that cost $100,000 or more.
III Equipment.
a Equipment includes movable personal property with a unit cost of $5,000 or more,
including sales tax, and delivery and installation charges.
b Additions to capitalized equipment costing $5,000 or more per item.
ATTACHMENT A
Administrative Bulletin No. 200
IV Infrastructure.
Capital Asset Accounting and Budgeting Policy
Page 2
a [nfrastructure assets are long-lived assets that normally are stationary in nature and can
be preserved for a significantly greater number of years than other capital assets.
b Infrastructure assets include roads, bridges, tunnels, drainage systems, water and sewer
systems, dams, and lighting systems.
V Intangibles.
a Intangible assets lack physical substance, have a non-financial nature, and have a useful life
that extends beyond a single reporting period.
b Examples of intangible assets include: easements, water rights, timber rights, patents,
trademarks, computer software, including internally generated software.
c Capitalization thresholds for intangible assets are as follows:
• $100,000 for all intangibles assets acquired after June 30, 2009 -excluding internally
developed or modified software and other internally developed intangibles.
• $1,000,000 for all internally developed intangible assets acquired after June 30, 2009.
• $1,000,000 for retroactive reported intangible assets.
Orig. Dept.: County Administrator, Auditor-Controller
Reference: Resolution No. 84/620
David J. Twa
County Administrator
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CONTRA COSTA COUNTY
Office of the County Administrator
ADMINISTRATIVE BULLETIN
Number: 205.1
Date: February 20, 2008
Section: Budget & Fiscal
SUBJECT: CASH – RECEIVING, SAFEGUARDING AND DEPOSITING
This bulletin establishes uniform procedures and standards for receiving, safeguarding
and depositing cash.
I. APPLICABILITY. This bulletin applies to all employees (including contractors,
temporary, agents or others) receiving or processing cash; their supervisors and
their managers.
II. DELEGATION OF AUTHORITY. All department heads, including elected officials,
are responsible for implementation of this bulletin. Any deviation requires prior
approval, in writing, from the County Auditor-Controller.
III. DEFINITION – CASH. Cash includes coins, currency, checks, postal and express
cash orders, traveler checks, bankers drafts, wire transfers, debit and credit cards
and any other payment device.
IV. GENERAL REQUIREMENTS. Every employee receiving cash is accountable for
all cash that he or she receives and such cash must be kept intact, secure, and
separate from other cash in the office. Receipts shall be prepared for all accepted
cash using one of the receipt forms approved by the County Auditor-Controller.
All customers must receive a receipt for their payment unless the payment is
received by mail and a receipt was not requested.
All cash received shall be delivered in a timely manner to the County Treasurer or
deposited to a bank account maintained by the County Treasurer with a
corresponding County deposit permit to the Treasury.
No County cash is to be maintained in an account in any financial institution,
bank, credit union or other depository without the knowledge and written
permission of the Auditor-Controller.
Internal Control Checklist for Cash details best practices on receiving,
safeguarding and depositing cash. Employees should periodically compare
their own practices to those detailed in the Checklist. Management must
also complete and submit the Checklist to the Auditor-Controller no later
than June 1st of every year.
ATTACHMENT B
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V. RECEIVING CASH. Cash may be received over the counter in the office or
through the mail.
A. Over the Counter Payments
1. Approved receipts must be issued for all payments.
2. Restrictive Endorsement – All negotiable instruments (non-cash form of
payment such as checks) must be restrictively endorsed immediately upon
acceptance using a stamp, which restricts payment for deposit only to the
County Treasury.
3. Payments must be deposited intact. Customers’ checks should be written
for the correct amount (no “cash back”). Employees may not cash
personal checks or exchange personal funds from the cash drawer.
4. Second party checks are not to be accepted.
5. No post-dated checks are to be accepted without a supervisor’s approval.
B. Through the Mail Payments
1.Restrictive Endorsement – All negotiable instruments (non-cash form of
payment such as checks) must be restrictively endorsed immediately upon
receipt using a stamp, which restricts payment for deposit only to the
County Treasury.
2.Second party checks are not to be accepted.
3. All checks received through the mail shall be recorded by the Mail Clerks
(team of two Clerks recommended) on a Mail List/Transfer Record
showing all relevant information, including the date, name of payer,
amount, client account to be credited, and the general ledger account to
be credited (if known). Photocopies of the checks received through the
mail may be made in place of separately listing each check. Mail Clerks
must retain a copy of the Mail List, including check photocopies, if the
original is transferred to another person for preparation of receipts.
4. Issuing Receipts - The person preparing receipts shall mail the original
receipt to the payer, if a receipt has been requested. The receipt
number(s), receipt date(s) and Deposit Permit (DP) number(s) shall be
recorded on the original Mail List. A copy of the completed Mail List shall
be kept on file.
5. Transfer Record – If the Mail Clerk does not prepare receipts, each person
handling cash must sign the original of the Mail List/Transfer Record until
it reaches the person designated to issue receipts. After issuing receipts,
that person shall make a copy to file and return the original Mail List to the
Mail Clerk. Note that each time the original Mail List changes hands, the
Transfer Record must be signed.
6.The mail clerk will retain the original Mail List at the work location until the
next Internal Audit Division audit.
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7.A department may establish an alternate procedure for cash received by
mail if approved in writing by the Auditor-Controller.
C.Recordkeeping.
1.One copy of the receipt shall be retained in the receipt book. Any receipts
not used (original or accounting copy) also shall be retained in the receipt
book.
2. Daily, every cashier shall count cash collected and document the
reconciliation of the count to the receipt records to identify any overage or
shortage. An employee not performing the receipting function shall review
reconciliations.
3. Cash collections shall be summarized daily on a cash receipt journal
showing receipt numbers issued, date receipted, amount receipted, and
revenue or other accounts to be credited. When the receipts are
deposited, the cash receipt journal shall show the deposit date and
Deposit Permit number.
4. Records Retention – Records substantiating cash receipts must be
retained at least until audited by the Internal Audit Division of the Office of
the Auditor-Controller.
Dependent upon the underlying type of transaction for the cash receipt,
there may be additional retention requirements.
D. Receipt Forms. Generally, receipts are issued on the County’s General
Receipts “F” (Form D-58) or “G” (Form D-57). However, cash register
receipts, computer-generated receipts, or other receipts may be used if pre-
approved in writing by the Auditor-Controller (stationary store receipts are not
authorized). Alternate forms will be considered for approval only if they meet
the following criteria:
1.Receipts are sequentially press or machine numbered.
2.Each receipt copy contains at least the following information:
a) Date of receipt.
b) Name of the person or institution from which the cash was received, a
reference to the specific county case, and account to which the
payment is applied. If no specific reference is applicable, then a
reference to a class of payment type is permissible (e.g. sale of forms,
copy charges, etc.).
c) Amount of payment.
d) Form of payment (cash, check, cash order, credit card, wire transfer,
etc.).
e) Name or identification code of the person receiving the cash.
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3. The issuing department must retain at least one duplicate copy of each
receipt. In lieu of a receipt, a report may be retained that is (or can be)
generated by the approved cash register or computer system that lists all
the above information.
4. Any voids must be authorized by a second person (preferably a manager).
E. Voided Receipts
1.The following information shall be recorded either in a voided receipt
register or on the voided receipt:
i. Reason for the void
ii. Replacement receipt number (if applicable)
iii. Supervisor’s signature
2. All copies of voided receipts shall be marked “voided” and retained in or
with the book and accounting copies. If the receipt is voided after the
payee has left with the original receipt, the original replacement receipt
shall be retained in or with the book and accounting copies of the voided
receipt.
3. Accountability must be established for all used and unused receipts.
VI.SAFEGUARDING CASH. All departments are responsible for providing
sufficient safeguards to prevent the loss of cash collected by the department as
well as customers’ financial information.
A. Each department is responsible for safeguarding sensitive information, such
as checking account numbers that may provide access to a customer’s
financial assets. Any officer or employee, who in the course of his or her
employment of duties has or has had access to credit card or payment device
information, shall not use, disclose or make known, in any manner,
information provided by customers for any unauthorized purpose.
B. Cash maintained at department offices must be kept in a locked and secure
location with access limited to authorized personnel only. If there is more
than one fund, the funds shall be secured in separate bags or lock-boxes.
Cash funds shall never be combined and monies from one fund shall not be
loaned to or used by another fund.
C. Management shall periodically conduct unannounced cash counts of
revolving funds (petty cash fund, change fund, cash difference fund) to verify
the amount of cash on hand and to ensure that the funds are being used for
authorized purposes. Also, management shall periodically verify the validated
Deposit Permit or bank deposit slip to the day’s receipts.
D. For proper separation of duties, the person having physical custody and
control of the cash shall not be authorized to approve expenditures.
E.Transfer of Accountability Record – When any cash is transferred from one
custodian to another custodian prior to deposit of the cash, the Transfer of
Accountability Record must be completed.
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VII. DEPOSITING CASH. Departments receiving cash shall deposit it in the County
Treasury in the manner described below, unless the department has made a
special arrangement with the County Treasurer for depositing the cash in a bank
account of the County Treasurer.
A. Deposit Requirements - If practical, daily depositing is preferred. If deposits
are not made daily, they shall be made when coin and currency exceed $250
or the total collections exceed $500. Deposits shall be made at least once a
month. All payments received shall be deposited in their entirety. Partial
deposits shall not be made. Any deviation from this practice must be
approved by the Auditor-Controller in writing.
B. Deposit Procedures -
1.Prepare a Deposit Permit Form D-34
2.Present the Deposit Permit to the counter clerk in the General Accounting
Division of the Auditor-Controller who will assign a deposit permit number.
The Deposit Permit, together with authenticated bank deposit slips, may
be mailed. Do not send cash through the mail. Employees may not trade
personal checks for cash. The General Accounting Division of the
Auditor-Controller will retain a copy of the Deposit Permit.
3.Take the copies of the Deposit Permit and the collections to the Office of
the County Treasurer for deposit.
4.The department keeps a copy of the Deposit Permit after endorsement by
the Auditor-Controller and the Treasurer. The copy is to be retained in the
department files. The Treasurer retains the original and a copy of the
Deposit Permit. After processing, the original is filed with the Auditor-
Controller.
C. For departments with County Treasurer-approved deposit arrangements.
1. Deposits made to a bank account of the County Treasurer shall be
prepared with a triplicate bank deposit ticket.
2. Copies of the bank-validated deposit ticket shall be distributed as follows:
•original to bank
•duplicate or second copy retained in office’s files
•triplicate copy attached to Deposit Permit which is sent to the Office of
the County Auditor-Controller.
Note: Deposit Permit numbers are available from the General
Accounting Division of the Auditor-Controller Office.
3.The Treasurer will notify the department of any returned checks. It is the
responsibility of the department to follow-up and collect on returned bank
checks.
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VIII. CREDIT CARD PAYMENTS. Accepting payments by credit card increases the
number of payment options and gives the customer greater flexibility. However,
the Department incurs additional expenses with credit card collections.
Departments accepting credit card payment must also conform to the Payment
Card Industry (PCI) Data Security standards for merchants.
A. Deposit Permits must be submitted to the Treasury for all credit card
deposits.
1.A “Host Totals” tape should be submitted to the Treasury with the
Deposit Permit. The detail for individual transactions should be kept
within the department to resolve any problems that may occur with
individual transactions.
2.Credit card fees cannot be netted against the revenue.
B. The full cost of the credit card program is the responsibility of the
accepting department. The costs include:
1. Start-up costs, including equipment, paper, and telephone lines.
2. Monthly fees.
3. Charges for invalid credit card transactions. This includes the principal
credit card amount charged as well as any fees and penalties charged
by the bank.
C. Payments for credit card program costs must be sent to the Treasury
monthly in a warrant or journal. Program costs should not exceed the
value of credit card payment deposits.
IX WIRE TRANSFERS. All wire transfers of funds into County bank accounts should
have a corresponding Deposit Permit submitted to the Treasury within 24 hours.
X. MANAGEMENT ACCOUNTABILITY. The Internal Control Checklist is an internal
control review to ensure accountability for cash in County departments. County
employees with oversight responsibility for cash in a department shall complete the
checklists no later that June 1st of every year. A current copy must be maintained
on file by the Department until the next audit. When completed a copy shall be
sent to the Chief Auditor, Internal Audit Division, Auditor-Controller’s Office.
XI. REFERENCES
Payment Card Industry (PCI) Data Security Standards
County e-Commerce Requirements
Originating Department: Office of the Auditor-Controller
Contact: Chief Auditor 925-646-2233
/s/_____________________________
JOHN CULLEN,
County Administrator
CONTRA COSTA COUNTY
Office of the County Administrator
ADMINISTRATIVE BULLETIN
Number: 212.1
Date: 10-24-75
Section: Budget & Fiscal
SUBJECT: Internal Audit of County Departments and Offices
Various California state codes require or authorize the County
Auditor-Controller to perform audits of the accounts and records of
specific County departments, offices and operations. In addition,
under the provisions of Section 26883 of the Government Code, the
County Auditor-Controller is an agent of the Board of Supervisors
in fulfilling its statutory responsibilities for audits of County
operations. The internal auditing function is performed by a staff
of professional auditors employed in the Internal Auditing Division
of the Office of the County Auditor-Controller.
PURPOSE
The objective of the County internal auditing function is to assist
County management in the proper and effective discharge of its
responsibilities by reviewing and evaluating financial records and
procedures and by providing reports to management containing
objective analyses, appraisals, comments and recommendations
concerning the activities reviewed.
The Internal Auditing Division has authority to review and appraise
such policies, plans, procedures and records as are necessary to
carry out its objective. This authority gives the Internal Auditor
full access to all pertinent County records, property, and
personnel except as limited by policy of the Board of Supervisors
and statutory requirements. As a staff function Internal Auditors
have no direct supervisory authority over those persons whose work
they review, nor does their review in any way relieve those persons
of the responsibilities assigned to them.
SCOPE
All County operations and activities are subject to internal audit
unless specifically exempted by statute or County policy.
Examinations are primarily financial in nature; however, the
Internal Auditor is concerned with all phases of County operations
wherein he can be of service to County management. Among the
activities of the Internal Auditing Division are the following:
1. Reviewing and appraising the soundness, adequacy and
application of accounting, financial and operating controls.
ATTACHMENT C
2. Examining accounting and related records maintained to account
for County revenues, expenditures, assets and liabilities, and
evaluating the reliability and adequacy of those records.
3. Determining the extent of compliance with statutory
requirements and with established policies and procedures
(particularly those relating to financial matters).
4. Ascertaining the extent to which County assets are accounted
for and the extent to which they are protected from losses of
all kinds.
5. Appraising the effectiveness of accounting and related
procedures and making recommendations for improvements.
6. Preparing audited financial statements for special County
operations. Special studies and financial analyses are also
performed from time to time.
PROCEDURES
Audits of most County departments are made on an annual basis at
about the same time each year. In certain circumstances, however,
audits may be performed more or less frequently than once a year.
Department officials are normally contacted by the Internal
Auditing Division in advance of the commencement of the audit to
arrange a mutually convenient time schedule and to discuss problem
areas and changes in department operations. In special
circumstances audits are sometimes made without advance notice.
Requests from departments for special reviews and analyses are
scheduled according to the urgency of their nature and the
availability of staff.
Upon completion of the audit a discussion draft of the report is
reviewed with the department. This is to assure agreement on
factual matters and give the department an opportunity for early
corrective action when required. The final written report is
directed to the responsible official with information copies to
others who are affected.
It is the responsibility of the official to whom the report is
directed to send a written reply to the County Auditor-Controller
within 30 days of the receipt of the report. When audit comments
or recommendations indicate that some specific action should be
taken, the reply must state what action has been or will be taken,
or the reason such action should not be taken.
Upon receipt of the reply, the County Auditor-Controller will
transmit an information copy of both the report and the reply to
the County Administrator for his review and desired action.
If no response is received within the 30-day time limit, the
information copy of the report alone will be sent to the County
Administrator with the notation that there has been no reply from
the responsible official. Subsequent replies will be sent to the
County Administrator separately, upon receipt.
CONCLUSION
Internal auditing is essential for proper management and control
purposes. All personnel should assist when contacted by the
internal audit staff in the performance of their studies and
analyses.
Orig. Dept.: County Auditor-Controller
Reference: California Government Code Section 26883
/s/ Arthur G. Will
_________________________
County Administrator
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CONTRA COSTA COUNTY
Office of the County Administrator
ADMINISTRATIVE BULLETIN
Number: 215.1
Date: March 24, 2008
Section: Budget & Fiscal
SUBJECT: PETTY CASH FUNDS
This bulletin establishes uniform procedures and standards for establishment, making
expenditures, replenishment and safeguarding of petty cash funds.
I.APPLICABILITY. This bulletin applies to all employees (including contractors,
temporary, agents or others) who are petty cash custodians and their supervisor.
II.DELEGATION OF AUTHORITY. All department heads, including elected officials,
are responsible for implementation of this bulletin. Any deviation requires prior
approval, in writing, from the County Auditor-Controller.
III.DEFINITION – PETTY CASH FUND. A small pool of coins and currency used to
make payment for small expenditures that cannot be made cost effectively through
other means. The petty cash fund may be a separate fund or a sub-fund within a
larger revolving fund (which may have multiple petty cash funds).
IV.GENERAL REQUIREMENTS.
All requests for new Petty cash funds or for increasing, reducing or abolishing
existing Petty cash funds must be directed to the Auditor-Controller in writing by
the department head or authorized representative requesting the change.
Requests for new Petty cash funds should describe the purpose(s) for which the
fund is needed, state the estimated size of fund required for such purpose(s), and
specify the means that will be used to protect the fund against loss or misuse.
Requests for changes in existing Petty cash funds should explain the need for the
change and contain documentation supporting the requested amount of the change.
V.ACCOUNTABLITY. A custodian shall be appointed for each Petty cash fund that
is responsible for the operation of the Petty cash fund. Alternate custodians may be
appointed, but the number should be limited. Operational and security
considerations should be evaluated when determining the number of alternate
custodians.
Management shall periodically conduct unannounced cash counts of Petty cash
fund to verify the amount of cash on hand and to ensure that the funds are being
used for authorized purposes.
ATTACHMENT D
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Appendix A – Internal Control Checklist (Petty cash) details best practices on
receiving, safeguarding and depositing Petty cash. Custodians should periodically
compare their own practices to those detailed in the Checklist. The Custodian’s
supervisor must also complete and submit the Checklist to the Auditor-Controller
annually by June 1.
VI.ESTABLISHMENT OF THE PETTY CASH FUND.
Upon approval of a petty cash fund, a warrant will be issued to the petty cash
custodian for the approved dollar amount. Petty cash funds are assigned a Vendor
number and name in the Accounts Payable section of the Office of the Auditor-
Controller. The initial check is issued under the vendor name (e.g. Rev Fnd – Dept
X) and not the name of the custodian. The custodian will need to take the warrant to
the bank or Treasurer and cash it. The custodian is the one responsible for
safeguarding the cash.
VII.EXPENDITURE PROCESS
Petty cash disbursements should be used for small incidental expenditures where
it would not be practical to make the disbursement by warrant. Each petty cash
transaction must be supported by an original voucher, receipt or invoice and signed
for by the recipient. If the original receipt is not available a memo explaining why it
is not available is required.
At all times the vouchers, receipts, and invoices plus the cash on hand should
equal the total amount of the Petty cash fund.
Appendix B – Petty Cash Log Form. All disbursements need to be logged on the
combination Demand and Cash Disbursement Voucher, form D15.11 or an alternate
form approved in advance by the Auditor-Controller. If there are not sufficient
lines on the D-15 form for the accounting information for all the transactions, record
all the accounting information on a separate TC 52 form and attach it to the D-15.
Petty cash may not be used for the following:
a)Cashing of personal or other checks
b)Personal loans or salary advances
c)Professional services
d)Employee meals
e)Gifts or gift cards
f)Alcohol
There may be operational considerations that require special handling of petty
cash expenditures. These must be approved in advance by the Auditor-Controller.
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VII.REPLENISHMENT
The Petty cash fund should be replenished as needed, usually monthly but at least
annually (before close of the County’s books on June 30). All replenishment
requests, form D15.11 must be accompanied by the original vouchers, receipts
and/or invoices. Receipts must be taped to an 8 ½ x 11 sheet of blank paper when
submitted. The D15.11 form and the related documentation is to be submitted to the
Accounts Payable unit of the Auditor-Controller for replenishment. The Accounts
Payable unit will then issue a warrant for the replenishment. Replenishment checks
are issued under the vendor name (e.g. Rev Fnd – Dept X) and not the name of the
custodian.
IX.SHORTAGES/OVERAGES
Shortages must be reported when discovered in accordance with the procedures in
Administrative Bulleting 207.7.
Overages must be reported when discovered. The overage is deposited to Fund
8109 for disposition.
Originating Department: Office of the Auditor-Controller
Contact: Chief Auditor 925-646-2233
/s/
JOHN CULLEN,
County Administrator
Page 1 of 14
CONTRA COSTA COUNTY
Office of the County Administrator
ADMINISTRATIVE BULLETIN
Number:
Date:
Section:
600.3
6/27/23
Purchasing
SUBJECT: Purchasing Policy and Procedures
Contents: I. DEFINITIONS
II.PURCHASE OF MATERIALS AND SUPPLIES
III.PURCHASE OF SERVICES CONTRACTS
IV.DIGITAL SIGNATURES
V.OTHER PROCUREMENT POLICIES
VI.OTHER ADMINISTRATIVE BULLETINS
The purpose of this bulletin is to set forth purchasing policies and requirements to achieve
minimum standards for the purchase of services, materials, supplies, equipment, furnishings,
and other personal property of any kind and nature for the benefit of County departments. More
information about compliance with this policy, including process, procedures and forms can be
found in the resources included in the “References” section at the conclusion of this policy.
I.DEFINITIONS
A.“Blanket Purchase Order” is an authorization to purchase developed by the
Purchasing Agent and issued on an annual or multi-year basis, that permits the
procurement of materials, supplies, equipment, furnishings, and other personal
property of any kind and nature on an as-needed basis with a stipulated
maximum amount for a fixed period of time and is used when there will be on-
going activity with a vendor. A blanket purchase order allows departments to
order a variety of goods from a single source as needed.
B.“Capital Outlay Item” is a piece of equipment including moveable personal
property with a unit cost of $5,000 or more, including sales tax, and delivery and
installation charges. It also includes additions to capitalized equipment costing
$5,000 or more per item 1.
C.“Cooperative Purchasing Contract” is a contract for goods or services between a
vendor and another public agency, awarded following a competitive solicitation,
and made available to other public agencies. Examples of agencies that administer
such Cooperative Purchasing Contracts include the National Intergovernmental
Purchasing Alliance (National IPA), the State of California, Department of General
Services, the U.S. General Services Administration, U.S. Communities
Government Purchasing Alliance sponsored by the National Association of
Counties, or similar entity. The County may participate in a Cooperative
Purchasing Contract by entering into a Participating Agreement with the vendor
1 See Administrative Bulletin No. 200, “Capital Asset Accounting and Budgeting Policy”
ATTACHMENT E
Page 2 of 14
that is party to the Cooperative Purchasing Contract.
D. “Equipment Capital Asset Code” is an expenditure account within the chart of
accounts reserved for purchase of certain Capital Outlay Items equal to or above
$5,000.
E. “Informal Bid” is a written or oral quotation obtained from an approved vendor but
not required to be opened publicly at a specified day, place and time.
F. “Invitation for Bid” (IFB) is a solicitation method by which awards are made to the
lowest bid. The winning bid must be responsive (conforms to bid requirements) and
responsible (competent and qualified to perform under the contract).
G. “Lease Purchase Agreement” is an agreement to rent equipment or property for a
period of time with the promise or option to acquire title at the end of the lease term.
H. “Participating Agreement” means an agreement between the County and a
vendor that incorporates by reference, with or without modifications, the terms of a
Cooperative Purchasing Contract that the vendor has entered into with another
public agency.
I. “Procurement Card” is form of credit card issued in an individual employee’s
name for use in making eligible purchases authorized by the Board of Supervisors
by Resolution on behalf of the County in compliance with County Ordinance Code
section 1108-2.224 and pursuant to regulations established in the Procurement
Card Manual authorized in Section II(B)(3)(b) of this policy.
J. “Purchasing Agent” is the office established pursuant to Article 1108-2.202 of the
County Ordinance Code.
K. “Purchasing Services” is the Purchasing Services division of the Public Works
department.
L. “Request for Information” (RFI) is a process to separate those vendors who
intend to participate in an upcoming solicitation from those who have no interest in
participating. An RFI is typically used when there is an excessively large pool of
interested vendors and to identify qualified suppliers capable of providing a certain
product or service. If an RFI is issued for an upcoming solicitation and a single,
qualified vendor responds to the RFI, then it is not necessary to conduct any
further Solicitation.
M. “Request for Proposal” (RFP) is a formal competitive procurement process and is
the most flexible method for obtaining contracted services and certain types of
goods. Responders to an RFP submit proposals detailing their technical and
business experience, capabilities, and specific approach to achieve the
requirements for the services or goods requested. An RFP includes evaluation
factors and criteria, and their relative importance for award selection. An RFP may
establish minimum or pre-qualification requirements to be eligible for consideration.
N. “Request for Qualifications/Quote” (RFQ) is a process to establish a pre-
qualified list of potential vendors by allowing interested parties to demonstrate
compliance with minimum qualifications or requirements to provide a material,
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product, or service. An RFQ may be used to initiate a formal procurement process
or to establish a pool of qualified vendors and may be released for a specific
amount of time or on a continuous basis to maintain a current qualified list of
vendors at all times.
O. “Requisition” is a request made by a County department head or designee to the
Purchasing Agent to order equipment and supplies.
P. “Single Source” is a procurement decision whereby purchases are directed to
one vendor because of standardization, warranty, or other factors, even though
other competitive sources may be available.
Q. “Special Services,” as defined in Government Code section 31000, are “services,
advice, education or training” in the following areas: “financial, economic,
accounting, engineering, legal, medical, therapeutic, administrative, architectural,
airport or building security matters, laundry services or linen services.” Special
services may include maintenance or custodial matters under certain
circumstances. For purposes of this bulletin, whether services contracted for are
“special services” requires consideration of factors such as the nature of the
services, qualifications of the person furnishing them, and their availability from
public sources. For example, services may be special because of the outstanding
skill or expertise of the person furnishing them.
R. “Sole Source” is a procurement decision created due to the inability to obtain
competition due to one vendor or supplier possessing the unique ability to meet the
particular requirements of the solicitation.
S. “Solicitation” is a purchasing entity’s request for offers to provide goods or
services, including an Informal Bid request for price quotations, an Invitation for
Bids (IFB), Request for Qualifications/Quote (RFQ), Request for Information (RFI)
or a Request for Proposals (RFP).
T. “Standard Purchase Order” is a document issued by the Purchasing Agent that
uses information from the Requisition to procure equipment and supplies at terms
and conditions most advantageous to the County.
II. PURCHASE OF MATERIALS AND SUPPLIES
A. Applicability.
This section establishes procedures for the Purchasing Agent to purchase
materials, supplies, equipment, furnishings, and other personal property of any kind
and nature and execute lease-purchase agreements on behalf of the County.
B. Procedures.
1. Purchase Orders.
a. Purpose. A Standard Purchase Order, Blanket Purchase Order, or
Participating Agreement may be used to purchase materials, supplies,
equipment, furnishings, and other personal property of any kind and
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nature.
b. General Terms and Conditions. All Standard Purchase Orders and
Blanket Purchase Orders (collectively “Purchase Orders”) shall include
the County’s “Purchase Order General Terms and Conditions,” which
are promulgated and updated from time to time by the Purchasing Agent
in consultation with County Counsel. By executing a Standard Purchase
Order or Blanket Purchase Order, a vendor agrees to abide by those
terms and conditions unless both the Purchasing Agent and vendor
agree in writing to amend any of those terms and conditions on behalf of
the County.
2. Requisitions.
a. Purpose: A Requisition is filed with the Purchasing Agent to order
materials, supplies, equipment, furnishings, and other personal
property of any kind and nature.
b. Submission. A Requisition must be submitted to the Purchasing Agent to
request the issuance of a Standard Purchase Order, Blanket Purchase
Order or Lease-Purchase Agreement.
c. Electronic Procurement System. The Purchasing Services division of
the Public Works department (“Purchasing Services”) shall provide an
electronic system to track the submission and processing of
Requisitions by departments and other purchasing logistics to comply
with any federal, state and local procurement requirements, including
this policy 2
d. Department Submission Authority. Department Heads are authorized to
prepare Requisitions on behalf of their respective departments and may
authorize designees to prepare Requisitions by submitting a written
authorization to the Purchasing Agent.
e. Fixed Asset Purchases. The appropriate Equipment Capital Asset Code
from the Chart of Accounts maintained and updated from time-to-time by
the Auditor-Controller must be applied to a Requisition for the purchase of a
Capital Outlay Item equal to or above $5,000.
When an Equipment Capital Asset Code is applied for a Capital Outlay
Item acquisition, the Requisition shall automatically route to the
Auditor-Controller to ensure that the requesting department has
adequate expenditure appropriations for the purchase. The Purchasing
Agent shall not proceed with the procurement of a Capital Outlay Item
until the availability of expenditure appropriations has been verified by
the Auditor- Controller. If expenditure appropriations are not available,
the Requisition will be returned to the requesting department. Capital
Outlay Item purchases shall be in compliance with Administrative
Bulletin No. 200, “Fixed Asset Accounting and Budgeting Policy”.
2 The current electronic procurement system is the “Purchasing Portal”, which is accessible at the following link:
https://purchasing.cccounty.us/bso/view/login/login.xhtml
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f. Emergency Purchase Orders. If a department needs to make an
emergency purchase pursuant to County Ordinance Code section 1108-
2.220, the “Emergency Purchase Form” must be signed by the
department head, or designee, and submitted to Purchasing Services
electronically with the invoice attached to initiate a purchase order to pay
the invoice.
3. Procurement Cards.
a. Purpose. County Ordinance Code section 1108-2.224 authorizes the Board
of Supervisors, by resolution, to authorize county departments to
purchase supplies, equipment, materials, goods and other personal
property without using the Purchasing Agent if a Procurement Card
authorized by the county Public Works department is used.
b. Manual. Resolution No. 2023/259 requires the Purchasing Agent to
establish a Procurement Card Manual outlining requirements for use of
procurement cards and identifying eligible purchases.
4. Warrant Requests.
a. Purpose. County Ordinance Code section 1108-2.222 authorizes the
Board of Supervisors, by resolution, to authorize county departments to
purchase services, supplies, equipment, materials, goods and other
personal property, regardless of cost, without using the Purchasing
Agent. Resolution No. 2023/260 outlines the process for making such
purchases and states that this Administrative Bulletin No. 600
establishes the list of eligible purchases.
b. Eligible Purchases. The following purchases may be made without
utilizing the Purchasing Agent regardless of dollar amount, unless
otherwise noted:
• association dues and membership fees;
• postage, including Federal Express (FedEx) and UPS;
• lodging;
• registration, including fees for conference booths;
• facility rental and food (subject to Administrative Bulletin No. 614, “Food
and Beverage Policy”)
• advertising;
• legal process service fees;
• public transportation fares and bridge tolls for employees;
• permits, fees, and licenses paid to governmental agencies;
• utility installation fees (Public Works department only);
• books, subscriptions and publications;
• legal notices;
• professional medical services payable by the Health Services
department based upon a specified fee schedule;
• expenditures mandated by the Court for the benefit of Wards of the
Court;
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• Other items below $5,0003, including:
o Computer hardware and software;
o commodities; and
o one-time services that are not covered under a service
contract and are authorized by the Purchasing Agent.
5. Receipt of Shipments. Departments are responsible for receiving
shipments of materials, supplies, equipment, furnishings, and other
personal property. To ensure that receipt of items is validated
appropriately, each department shall ensure the following:
a. Preparing for Receipt. Each department shall have a physical location
and identify specific staff members responsible for receiving and
inspecting shipments and establish procedures for receiving shipments
and verifying shipment contents.
b. Physical Inspection. Shipments should be physically inspected by
department staff upon arrival to ensure the contents match the original
order specifications. Contents should be inspected for damage and
completeness with any issues documented.
c. Documentation. Records of essential information related to receipt of
shipments should be maintained such as date and time of inspection,
shipment details, including the supplier’s name, Purchase Order
number, accompanying documentation such as packing slip or invoice
and whether any items were damaged, not received or failed a quality
control test. In addition, any communication with the supplier related to
incomplete or damaged items should be maintained.
6. Solicitations Required. The following solicitations are required for
purchases of materials, supplies, equipment, furnishings, and other
personal property of any kind and nature in the following amounts.
a. Purchases Equal to or Below $25,000.
1. A department may request a Purchase Order for a purchase equal to
or below $25,000 without providing evidence of solicitation.
Departments are encouraged to purchase from local businesses, small
businesses, women-owned businesses, disabled-owned businesses,
veteran-owned businesses, and other disadvantaged business
enterprises for a purchase equal to or below $25,000.
b. Purchases Above $25,000 and Equal to or Below $100,000.
1. A department shall request a Purchase Order for a purchase above
$25,000 and equal to or below $100,000 after securing a minimum of
three (3) price quotes, with at least one (1) price quote from a Small
Business Enterprise (SBE) provider, through an Informal Bid.
3 Items costing $5,000 or above are not eligible to be processed on a Warrant Request.
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2. If three (3) price quotes cannot be secured, or an SBE provider
cannot be identified, the Purchasing Agent shall determine
whether to proceed with the purchase by taking into consideration
the vendor that provides the best value to the County.
c. Purchases Above $100,000.
1. A department shall conduct an open and competitive solicitation for
a purchase above $100,000. The form of solicitation may be an
Invitation for Bid (IFB), a Request for Qualifications/Quote (RFQ),
Request for Information (RFI) or a Request for Proposals (RFP).
2. A department shall submit a Requisition that includes detailed
specifications of the materials or supplies being requested.
3. Purchasing Services shall work with the requesting department to secure
a minimum of three (3) solicitation responses in writing before selecting a
vendor. Purchasing Services shall post the solicitation online to comply
with the fair and open competition requirements of this policy for a
minimum of fourteen (14) calendar days.
d. Exemption from Solicitation Requirements.
1. Sole/Single Source Justification. A department may submit a
Requisition with a completed Sole Source Justification Form for
consideration by the Purchasing Agent to seek exemption from
solicitation requirements in the following specific cases:
A. Sole Source. One vendor or supplier possessing the unique ability to
meet the particular requirements; or
B. Single Source. One vendor because of standardization,
warranty, or other factors, even though other competitive
sources may be available.
The Purchasing Agent has the sole discretion to approve or reject
single/sole source exemption requests.
2. Cooperative Purchasing Contracts. In lieu of a bid solicitation process,
a department may request that Purchasing Services initiate a
Cooperative Purchasing Contract for goods that the County requires
and that the County may procure under a Participating Agreement.
Purchasing Services will initiate County Counsel review of
Cooperative Purchasing Contracts, with the exception of those related
to the Health Services Department, which initiates County Counsel
review directly.
7. Approvals. The following approvals are required for each purchase category
below.
a. Purchases Equal to or Below $200,000. The department requesting a
purchase equal to or below $200,000 shall file a Requisition that
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complies with this policy for review and approval by the Purchasing
Agent.
b. Purchases Above $200,000. A purchase above $200,000 complying
with this policy requires approval by the Board of Supervisors. The
requesting department shall draft a Board Order seeking approval of the
purchase above $200,000 and submit to the County Administrator’s
Office via the Board of Supervisors’ electronic agenda management
system for placement on the Board of Supervisors’ agenda for review
and final approval.
8. Participating Agreements. A Participating Agreement must be approved by
the Board of Supervisors, subject to review by County Counsel, if the
payment limit exceeds $200,000, or if the Participating Agreement and/or
underlying contract includes any term requiring the County to indemnify the
vendor, or any term that limits the vendor’s liability.
9. Documentation. All solicitation and approval documents required by this
policy must be submitted electronically to Purchasing Services with the
Requisition for purchase.
C. Services Included Under a Purchase Order. In certain circumstances, the
Purchasing Agent may determine that services provided by a vendor in
conjunction with the purchase or lease of materials, supplies, equipment,
furnishings, and other personal property of any kind and nature from the same
vendor is appropriate. The Purchasing Agent is authorized to execute a Purchase
Order that authorizes the vendor to provide services if:
1. The Purchase Order includes all contract development and monitoring
procedures specified in Section III(B)(7) of this policy;
2. The department requesting the Purchase Order complies with all contract
development procedures specified in Section III(B)(7) of this policy; and
3. Service agreements submitted on a vendor standard form must be reviewed
by County Counsel.
D. Ethical Standards. It is the obligation and the responsibility of every County
employee to represent the County in a professional and ethical manner. Any
procurement related matter shall be handled in a professional manner with the
interest of the County taking precedent, including, but not limited to:
1. Avoiding activities which would compromise or give the perception of
compromising the best interests of the County;
2. Actively promoting the concept of competition through bid solicitation
consistent with this policy; and
3. Refraining from engagement in any procurement activity in which an
employee may have a personal or indirect financial interest in accordance
with Government Code sections 87100 and 81703.
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E. Legal Authority. The legal authority for the Purchasing Agent to purchase
materials, supplies, equipment, furnishings, and other personal property of any
kind and nature on behalf of the County is set forth in the following statutes and
County codes: Government Code sections 25500- 25509, 31000; Public Contract
Code sections 22002(d) and 22032; and County Ordinance Code chapter 1108-2.
III. PURCHASE OF SERVICES CONTRACTS
A. Applicability.
This section establishes procedures for the purchase of services required by
the County. State law provides that the Board of Supervisors may contract for
services on behalf of the County or any County officer or department under
certain circumstances. The Board of Supervisors has authorized the
Purchasing Agent to enter into service contracts costing not more than
$200,000. Service contracts exceeding $200,000 require approval by the Board
of Supervisors, following review by the Office of County Counsel and the
County Administrator.
B. Procedures for Service Contracts.
1. Mandated Findings. Before a contractor for services is engaged, all of the
following findings must be made and documented by the department.
a. A statute authorizes the contract for the desired services. For
example, Government Code section 31000 authorizes the
Board of Supervisors to enter into a service contract for Special
Services;
b. County staff is not available or qualified to perform the services; and
c. In the case of facilities maintenance or custodial matters, the site is
remote from available County employee resources and the County's
economic interests are served by contracting for such services rather
than by paying additional travel and subsistence expenses to existing
County employees.
2. Solicitations Required. The following solicitations are required for
purchase of services in the following amounts.
a. Service Contracts Equal to or Below $25,000.
1. A department may enter into service contracts equal to or below
$25,000 without providing evidence of solicitation.
2. Departments are strongly encouraged to purchase from local
businesses, small businesses, women-owned businesses, disabled-
owned businesses, veteran-owned businesses, and other
disadvantaged business enterprises consistent with the County’s
Outreach and SBE program goals so they may achieve the County's
objective of awarding 50% of total eligible dollar base amounts to
SBEs.
Page 10 of 14
b. Service Contracts Above $25,000 and Equal to or Below $100,000.
1. A department may enter into a service contract above $25,000 and equal
to or below $100,000 after securing a minimum of three (3) proposals
through an Informal Bid.
2. If three (3) proposals cannot be secured, the Purchasing Agent, or
designee, shall determine whether to proceed with the service
contract taking into consideration the vendor that provides the best
value to the County.
3. Departments are strongly encouraged to purchase from local
businesses, small businesses, women-owned businesses, disabled-
owned businesses, veteran-owned businesses, and other disadvantaged
business enterprises consistent with the County’s Outreach and SBE
program goals so they may achieve the County's objective of awarding
50% of total eligible dollar base amounts to SBEs.
c. Service Contracts Above $100,000.
1. A department may enter into a service contract above
$100,000 after providing for open and competitive solicitation.
2. The form of solicitation may be an Invitation for Bid (IFB), Request for
Qualifications/Quote (RFQ) or a Request for Proposals (RFP);
however, a department should consider initially issuing a Request for
Information (RFI) to generate a list of potential vendors to provide the
services required. If a department receives a single response to the
RFI from a qualified bidder, then no further solicitation is required.
3. Departments are strongly encouraged to purchase from local
businesses, small businesses, women-owned businesses, disabled-
owned businesses, veteran-owned businesses, and other
disadvantaged business enterprises consistent with the County’s
Outreach and SBE program goals so they may achieve the County's
objective of awarding 50% of total eligible dollar base amounts to
SBEs.
3. Solicitation Compliance Procedure.
a. The department shall draft and Purchasing Services may provide
counsel on an IFB, RFQ, RFI or RFP seeking qualified vendors to
provide the desired services.
b. Purchasing Services shall post the solicitation online to comply with the
fair and open competition requirement of this policy for a minimum of
fourteen (14) calendar days.
c. Purchasing Services shall work with the requesting department to secure
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a minimum of three (3) solicitation responses in writing before selecting a
vendor.
d. Purchasing Services shall retain solicitation records for the duration
of each contract term.
4. Exemption from Solicitation Requirements.
a. Service Types. The following are service contract types that are exempt
from bid solicitation requirements:
• utility services;
• educational services;
• intergovernmental agreements;
• newspaper and publication services;
• law firms, subject to approval by the County Counsel’s Office;
• print legal briefs or legal notices;
• reporters services or transcripts;
• expert witnesses, consultants, and investigators hired through the
County Counsel’s Office to assist in legal matters;
• election supplies;
• expert services to be rendered to the offices of the District
Attorney or Sheriff-Coroner;
• physician services at the Contra Costa Regional Medical Center
(CCRMC) or the Contra Costa Health Plan (CCHP);
• appraiser services;
• consultants and other experts employed directly by the Board of
Supervisors; and
• other services that, by law, some other officer or body is specifically
charged with obtaining.
b. Cooperative Purchasing Contracts. A department may submit a
Requisition identifying a Cooperative Purchasing Contract for services
that County requires and that the County may procure under a
Participating Agreement.
5. Ethical Standards. It is the obligation and the responsibility of every County
employee to represent the County in a professional and ethical manner. Any
procurement related matter shall be handled in a professional manner with
the interest of the County taking precedent, including, but not limited to:
a. Avoiding activities which would compromise or give the perception of
compromising the best interests of the County;
b. Actively promoting the concept of competition through bid
solicitation consistent with this policy; and
c. Refraining from engagement in any procurement activity in which an
employee may have a personal or indirect financial interest in
accordance with Government Code sections 87100 and 81703.
Page 12 of 14
6. Outreach and SBE Program Compliance. Additional thresholds and goals
under the County Outreach and SBE (Small Business Enterprise) programs
apply to and are required for service contract solicitations. These thresholds
and goals may be updated from time to time and departments must ensure
compliance with the latest Outreach and SBE Program construct.
7. Contract Development and Monitoring. Department Heads are responsible for
the development and monitoring of service contracts entered into on behalf of
each County department, including negotiation of service plans and/or scopes
of work.
a. Performance Metrics Required. Departments are responsible for
negotiating service contracts that identify specific performance outputs
and/or outcomes to be achieved during the contract term. These
performance outputs and/or outcomes include contract deliverables (e.g.,
produce a final written report by a date specified) and/or service tasks
(e.g., conduct three one-hour training sessions within a specified date
range). Contracting departments shall review contracts at least once per
year to ensure compliance with output/outcome requirements. The review
should identify reason(s) for any noncompliance, including whether or not
the outputs/outcomes will be achievable during the remainder of the
contract term.
b. Payment Provisions. Vendor payment terms shall correlate with the
performance outputs/outcomes negotiated as part of a service plan or
scope of work for each service contract. Types of payment terms include
fixed price (where deliverables are produced by the contractor and
payment is due upon completion of each deliverable) and rate (where
services are provided by the contractor and the contractor is reimbursed
at an hourly or other periodic rate). Departments shall avoid contract
payment terms that are not typical of the service type being procured.
For example, legal service providers may require payment of an
advance, or “retainer”, upon execution of a service contract, which is
typical of that industry. However, a financial consultant requesting a
monthly, fixed payment as a “retainer,” whether or not the County uses
the contracted services, is not a typical financial industry practice and
must be avoided. Other negative payment terms, such as late payment
penalties, should not be entertained as part of the negotiation of
payment terms.
c. Vendor Noncompliance. Failure of a vendor to achieve contracted
performance output and/or outcome requirements may be grounds for
contract termination.
d. Corrective Action Plan. For contracts determined to be out of compliance
with performance outputs and/or outcomes during an annual review
process, and for which a department does not recommend terminating
the contract, the department shall work with the vendor on a corrective
action plan to ensure contracted services are delivered during the term of
the contract.
e. Documentation. Departments shall immediately notify a vendor if a
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determination of non-compliance is reached. Including whether or not the
contract will be recommended for termination, with a copy to Purchasing
Services. In cases where a Corrective Action Plan is entered into with the
vendor, a copy of the plan shall be forwarded to Purchasing Services and
retained by the department for the term of the contract.
f. Renewals. Departments shall keep track of contract expiration dates in
order to renew contracts prior to expiration, or issue solicitations for new
contracts to be in place prior to expiration of the existing contract.
8. Effective Date. Service contract documents must be executed before the
service contract effective date. Contract payments cannot be made until the
service contract is executed by all parties.
9. Indemnification. Any contract that requires the County to indemnify the
contractor, or includes a limitation of liability, must be approved by the Board
of Supervisors regardless of the contract amount.
C. Procedures for Services Contracts Equal to or Below $200,000.
1. Approval. The Purchasing Agent is authorized to execute contracts for
services costing equal to or below $200,000.
2. County Counsel Review. A service contract that is either more than
$50,000 or not on a County standard form (i.e., on a vendor’s form)
must be reviewed and approved as to legal form by the County
Counsel’s Office before the Purchasing Agent executes the contract.
If a service contract is $50,000 or less and is on the County’s
standard form, the Purchasing Agent may sign the contract without
County Counsel review.
D. Procedures for Service Contracts Above $200,000.
1. Approval. The Board of Supervisors must approve all service contracts
above $200,000. The requesting department shall draft a Board Order
seeking approval of the contract over $200,000 and submit to the County
Administrator’s Office via the Board of Supervisors’ electronic agenda
management system for placement on the Board of Supervisors’ agenda for
review and final approval.
2. County Counsel Review. All service contracts that are over
$200,000 must be reviewed and approved as to legal form by the County
Counsel’s Office.
E. Legal Authority. The legal authority for the purchase of certain services required
by the County is set forth in the following statutes and County codes: Government
Code section 31000, Government Code section 25502.5, Ordinance Code section
1108-2.215 and Public Contract Code section 22032(a).
IV. DIGITAL SIGNATURES. All purchasing and contract related documents specified in this
bulletin may be executed either with original signatures or electronic signatures through a
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digital signature platform authorized by the Chief Information Officer.
V.OTHER PROCUREMENT POLICIES. The Board of Supervisors, in its discretion, may
adopt additional policies impacting procurement of materials, supplies, equipment,
furnishings, and other personal property of any kind and nature or services from time to
time. This policy establishes the minimum standards for conducting procurement activities;
however, compliance with additional policies adopted by the Board of Supervisors or those
required to satisfy federal or state grant requirements may supersede this policy.
VI.OTHER ADMINISTRATIVE BULLETINS. Additional Administrative Bulletins governing
specific purchases have been promulgated to provide guidance on those unique
transaction types and should be reviewed in conjunction with this policy as the
requirements in those policies may supersede the requirements in this policy, including:
a.Administrative Bulletin No. 508, “County Vehicle and Equipment Acquisition and
Replacement Policy, and Zero-Emission Vehicle Policy and Goals”.
b.Administrative Bulletin No. 614, “Food and Beverage Policy”.
c.Administrative Bulletin No. 615, “Incentives for County Programs and
Services”
d.Administrative Bulletin No. 616, “Acquisition of Computer Hardware,
Software and Computer-Related Services”.
References:
•Emergency Purchase Form
•Procurement Card Manual
•Purchasing User Setup/Change Form
•Sole Source Purchase Form
•Purchase Order General Terms and Conditions
•Small Business Enterprise (SBE) Program Requirements
Monica Nino,
County Administrator
/s/
BOS Approved: June 27, 2023, Agenda Item C.107
Page 1 of 3
Community Services Bureau
FIXED ASSETS, INFORMATION TECHNOLOGY, LOW-VALUE INVENTORY AND
CLOUDS DATA SYSTEM POLICIES AND PROCEDURES
BACKGROUND
The following Agency Fixed Assets, Information Technology, Low-value Inventory
and CLOUDS Data System Policy was approved by Community Services Bureau ("CSB").
This policy applies to all programs funded by CSB.
DEFINITIONS
General Fixed Assets: All equipment (non-expendable personal property) with an
acquisition cost of $5,000.00 or more per unit and a useful life of more than one year that
is purchased with funds distributed by CSB.
Information Technology Equipment (purchased with CSB Program funds): The
purchase, rent, licensing, maintenance fee, or subscription of information-technology
applications/software/services with a per-unit single or cumulative cost totaling $5,000 or
more within a twelve-month period with CSB Program funds.
Low-value Inventory (Equipment): All computer hardware and expendable property
of a sensitive nature (subject to loss or theft due to its size), meeting the state and federal
definition of equipment, such as photocopiers, printers, tablets, laptops, and video
cameras with an estimated useful life of more than one year, and value is less than
$5,000.00. All Low-value Inventory shall be considered to have a useful life of up to five
years for purposes of this policy.
Covered Equipment: Any and all General Fixed Assets, Information Technology
and/or Low-value Inventory. The cost of Covered Equipment includes: the purchase price
less discounts plus freight charges; sales, use and transportation taxes; and installation
charges.
CLOUDS Data Management System (Software): all programs operated and funded by
CSB, including sub-recipient/delegate/partner, will utilize the CLOUDS data management
system for recording daily attendance, reports, asset management and conduct program
monitoring. County shall provide training and technical support on CLOUDS and all related
hardware and software applications used at sub-recipient/delegate/partner centers, on an
as-needed basis.
PRlOR APPROVAL OF FIXED ASSETS AND INFORMATION TECHNOLOGY
Expenditures for fixed assets and information technology (CSB Program funds)
shall be approved by CSB and/or grantor prior to the purchase of such fixed assets by
subrecipient/delegate agency. Sub-recipient/delegate/partner agency shall obtain written
approval of CSB and/or grantor prior to purchasing the fixed assets and information
ATTACHMENT F
Page 2 of 3
technology. For fixed assets purchase using Head Start funds, if fixed assets are
approved in the annual budget, no further approvals are required.
INVENTORY OF FIXED ASSETS AND LOW-VALUE INVENTORY
All Covered Equipment will be inventoried by Sub-recipient/Delegate/Partners and
entered into CLOUDS Asset Management System, which will be monitored by CSB. A
physical property inventory monitoring will be conducted and reconciled with the property
records at least once every two years. Replacement, transfer, tagging and disposal of
any Covered Equipment shall be consistent with the following procedures.
REPLACEMENT OF COVERED EQUIPMENT
When the status of Covered Equipment is reported after the annual physical
inventory, the sub-recipient/delegate/partner agency that cannot locate items of Covered
Equipment assigned to it shall provide to CSB (from non-CSB sources) funds equal to the
replacement Value of the Covered Equipment not located.
TRANSFER OF COVERED EQUIPMENT
The sub-recipient/delegate/partner agency that receives Covered Equipment from
CSB will be solely responsible for the pickup and return of such equipment to CSB. In
addition, all Covered Equipment must be returned when the program operator is no longer
funded by CSB.
TAGGING OF COVERED EQUIPMENT
Every purchase made with CSB funds will be approved by CSB's Fiscal Unit. Each
sub-recipient/delegate/partner must be aware that in some instances, prior federal and/or
state approval is necessary, and program must secure the appropriate approval prior to
acquisition. For tagging and record keeping, the sub-recipient/delegate/partner must
provide a report containing an itemized listing of Covered Equipment purchases with a
copy of the invoice for each item. The listing should provide the date of acquisition,
individual cost, serial number, and location of the Covered Equipment. CSB will then
arrange for tagging the Covered Equipment.
DISPOSITION OF COVERED EQUIPMENT
Disposition of Covered Equipment will be made in accordance with OMB Uniform
Guidance (2 CFR Part 200) and applicable implementing regulations by federal funding
source. Sub-recipient/delegate/partner agency shall also take reasonable measures to
safeguard and protect personally identifiable information from the Covered Equipment in
accordance with OMB Uniform Guidance (2 CFR Part 200.82 and 200.203(e)). Covered
Equipment determined to be non-usable by CSB may be. sent to the County General
Services for disposition. Proceeds received from disposition will be retained by CSB for
future program services, as applicable to each funding source.
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If it is determined that the cost of moving the non-usable Covered
Equipment will exceed the potential sale proceeds from disposition, CSB may
perform disposition procedure on site. In addition, any Low-value Inventory that
has exceeded its useful life may be disposed of on site. If any Covered Equipment
is disposed of on site, the Program Operator shall continue to use such equipment
in its CSB-funded program or, if such equipment is disposed of for value, the
proceeds shall be considered Program Income and shall be accounted for as
provided in the sub-grant or delegate agreement.
CLOUDS DATA MANAGEMENT SYSTEMS
Sub-recipient/Delegate/Partner shall use CLOUDS data management system,
including specific software applications and hardware, for all enrollments using CSB's
state or federal funding for the following:
1)Electronic Attendance/e-Signature/Touchless QR Code sign-in/out system
2)Communication with Families (SMS, Email & CSBConnect.org)
3)DROP App data recording
4)Program Information Report (PIR)
5)Monitoring
6)Purchase Request Approval Process (CLOUDS & CSBConnect.org)
7)Electronic Communications via SMS, Email & CSBConnect.org
8)Asset Management Module (Federal & State Funding)
REPORTS AND SUBMITTALS
Recipient and sub-recipient/Delegate, shall conduct a physical inventory of the
property and results reconciled with the property records in CLOUDS asset
Management at least once every two years and complete the approved Equipment
Inventory Form/Template provided (see Exhibit 1, attached).
1) County shall provide CLOUDS specific hardware and software applications for
electronic attendance requirements.
2)Hardware is the property of the County, and the below procedures must be
followed:
a)Missing or Stolen County hardware must be reported to CSB and
include a copy of police report.
b)Non-operational or damaged hardware must be returned to CSB as
soon as possible and a replacement will be provided
c)All County hardware must be returned upon termination of
contract agreement.
Equipment Inventory
Item Description*Serial or Identification
Number
Original Cost Acquistion Date Source of Funding (incl.
FAIN)
Who Holds Title % of Federal
Interest**
Location Use Condition Disposition Date (incl. date of disposal
and sale price)***
Example: King-Wade desktop computer 12345678-9011 $1,500 7/12/2004 B.L. Warren Preschool ACF 50
Example: Metover refrigerator 23434234-90 $1,200 2/13/1995 Transfer to U.L. Max C.D.C.
Page of
Equipment Inventory
Contractor Legal Name:Funding Source (e.g. ACF)
***Enter date the item was removed from service and its disposition.
References: Head Start Act’s Post Federal Award Requirements regarding Equipment (see 45 Code of Federal Regulations section 75.320(d)(1)(Equipment)).
Note: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.
I certify the information contained in this Equipment Inventory form represents a complete and accurate disclosure of
items purchased with Head Start funds.
Signature Inventory Completion Date
* List each piece of equipment, purchased in whole or part, with funds provided by ACF. **Enter percentage of Federal participation in the project costs for the Federal award under which the property was acquired
EXHIBIT TO ATTACHMENT E
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
TABLE OF CONTENTS
SECTION / SUBJECT PAGE
GENERAL: ...................................................................................................................... 3
REFERENCES: ............................................................................................................... 3
PURPOSE: ....................................................................................................................... 3
DEFINITIONS:................................................................................................................ 4
WHO MUST COMPLY: ................................................................................................. 5
POLICY STANDARDS FOR FISCAL MONITORIING: ............................................. 5
POLICY GUIDANCE AND REFERENCES: .............................................................. 10
A.Subrecipient/Contractor Determination ..............................................................10
B.Risk-based Approach to Evaluating Risks Posed by Subrecipient Applicant ....11
C.Incorporation of Subrecipient Language and Evaluation of Subrecipient
Budget for Reasonableness, Allocability and Allowability ................................12
D.Required Information in Subaward .....................................................................15
E.Evaluation Factors to Assess Subrecipient’s Risk of Noncompliance ...............17
F.Monitoring of Subrecipient Fiscal Activities ......................................................19
G.Report on Cumulative Federal Subaward Payments to Subrecipient .................21
H.Subrecipient Subject to Single Audit Requirements ...........................................21
I.Review of Subrecipient Single Audit .................................................................22
J.Issuance of Management Decision and Subrecipient Corrective Actions ..........22
K.Additional Specific Award Conditions upon a Subrecipient as Appropriate .....23
L.Remedies for Noncompliance of 2 CFR 200 and in Program Regulations ........24
M.Subrecipient Monitoring Standards and Tracking Subrecipient Monitoring
Activities .............................................................................................................24
N.Foster Family Agency (FFA) and Group Home Monitoring and Oversight ......25
O.Fiscal Monitoring in the Aging and Adult Bureau .............................................25
P.Fiscal Monitoring in the Workforce Development Board Bureau ......................25
ATTACHMENT G
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Q. Fiscal Monitoring and Head Start/Early Head Start Regulations on the
Allowability of Costs and Inventory Requirements in the Community Service
Bureau .................................................................................................................25
ROLES, RESPONSIBILITIES AND DATA MANAGEMENT .................................. 27
APPENDIX 1: SUBRECIPIENT/CONTRACTOR DETERMINATION CHECKLIST ............ 33
APPENDIX 2: CONTRACT BUDGET REVIEW CHECKLIST ............................................... 36
APPENDIX 3: SPECIAL CONDITIONS TEMPLATE .............................................................. 39
APPENDIX 4: SUBRECIPIENT QUESTIONNAIRE ................................................................ 42
APPENDIX 5: RISK ASSESSMENT MATRIX ......................................................................... 53
APPENDIX 6: SUBRECIPIENT MONITORING PLAN ........................................................... 56
APPENDIX 7: GUIDELINES TO REVIEW MONTHLY DEMANDS ..................................... 59
APPENDIX 8: DESK REVIEW GUIDE ..................................................................................... 63
APPENDIX 9: ONSITE MONITORING GUIDE ....................................................................... 72
APPENDIX 10: FEDERAL AWARD PAYMENT TEMPLATE ............................................... 87
APPENDIX 11: SINGLE AUDIT CERTIFICATION ................................................................. 89
APPENDIX 12: AUDIT REVIEW CHECKLIST ........................................................................ 92
APPENDIX 13: MANAGEMENT DECISION TEMPLATE ..................................................... 98
APPENDIX 14: CORRECTIVE ACTION LETTER TEMPLATE ........................................... 103
APPENDIX 15: COMMUNITY SERVICE BUREAU – SELF-MONITORING TOOLS ....... 109
APPENDIX 16: EHSD PROCESS FOR CHARGING COSTS TO HEAD START ............... 125
APPENDIX 17: EHSD DELEGATE ONSITE MONITORING TOOL ................................... 135
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
GENERAL:
This document establishes the Employment and Human Services Department (EHSD)
fiscal monitoring policy on the oversight responsibilities relating to federal subawards
made to subrecipients.
REFERENCES:
Title 2 - Code of Federal Regulations, Part 200, Grants and Agreements;
Title 45 - Code of Federal Regulations, Public Welfare;
Title 29 - Code of Federal Regulations, Labor;
Federal Acquisition Regulations (FAR) Part 31, Cost Principles and Procedures for
Commercial Entities;
Federal Acquisition Regulations (FAR) Part 48, Cost Accounting Standards for Commer-
cial Entities; and
Other applicable Title(s) as indicated in grant agreement(s).
PURPOSE:
As a pass-through entity of federal funds, it is EHSD’s policy to monitor its subrecipients
consistent with the requirements outlined in this document.
Federal rules, unless otherwise stated in applicable CFRs, require pass-through entities to
evaluate each subrecipient's risk of noncompliance to determine the appropriate fiscal
monitoring level, monitor the fiscal activities of subrecipient organizations to ensure that
the subaward is in compliance with applicable Federal statutes and regulations and terms
of the subaward, and verify that subrecipients are audited as required by Subpart F of 2
CFR 200 and 45 CFR Part 75.
Failure to adequately monitor the fiscal compliance of subrecipients could result in audit
findings in EHSD’s single audit report or fiscal monitoring report conducted by Federal
and State monitors. EHSD, as a pass-through entity, serves as a steward that exercises the
appropriate oversight to provide reasonable assurance that Federal awards are expended
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
in accordance with programmatic intent and are not misapplied, or misdirected whereby
financial harm may be suffered by EHSD, Contra Costa County, and/or its constituency.
The standards in this policy apply to all subrecipients of federal awards, unless otherwise
stated in applicable CFRs.
DEFINITIONS:
Subrecipient – Title 2 CFR section 200.93 and 45 CFR 75.2
Subrecipient means a non-Federal entity that receives a subaward from a pass-
through entity to carry out part of a Federal program; but does not include an individ-
ual that is a beneficiary of such program. A subrecipient may also be a recipient of
other Federal awards directly from a Federal awarding agency.
Contractor – Title 2 CFR section 200.23 and 45 CFR 75.2
Contractor means an entity that receives a contract as defined in §200.22 contract.
Subaward – Title 2 CFR section 200.92 and 45 CFR 75.2
Subaward means an award provided by a pass-through entity to a subrecipient for the
subrecipient to carry out part of a Federal award received by the pass-through entity. It
does not include payme nts to a contractor or payments to an individual that is a bene-
ficiary of a Federal program. A subaward may be provided through any form of legal
agreement, including an agreement that the pass-through entity considers a contract.
Contract – Title 2 CFR section 200.22 and 45 CFR 75.2
Contract means a legal instrument by which a non-Federal entity purchases goods or ser-
vices needed to carry out the project or program under a Federal award. The term as used
in this part does not include a legal instrument, even if the non-Federal entity considers it
a contract, when the substance of the transaction meets the definition of a Federal award
or subaward (see §200.92 Subaward).
Pass-through Entity – Title 2 CFR section 200.74 and 45 CFR 75.2
Pass-through entity means a non-Federal entity that provides a subaward to a subrecipi-
ent to carry out part of a Federal program. This will generally refer to EHSD.
Non-federal Entity – Title 2 CFR section 200.69 and 45 CFR 75.2
Non-Federal entity means a state, local government, Indian tribe, institution of higher ed-
ucation (IHE), or nonprofit organization that carries out a Federal award as a recipient or
subrecipient.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Cognizant Agency for Indirect Cost – Title 2 CFR section 200.19 and 45 CFR Part 75.2
Cognizant agency for indirect costs means the Federal agency responsible for reviewing,
negotiating, and approving cost allocation plans or indirect cost proposals developed un-
der this part on behalf of all Federal agencies.
WHO MUST COMPLY:
EHSD as a pass-through entity providing subawards to subrecipients to carry out part of a
federal program(s) must comply with this policy.
Fiscal staff will be implementing the standards in this policy. Program analysts and their
designees will work in collaboration with fiscal to assist with the coordination of fiscal
monitoring activities and be involved in the resolution of fiscal monitoring findings.
POLICY STANDARDS FOR FISCAL MONITORIING:
Title 2 CFR section 200.331 defines the requirement for pass-through entities awarding a
federal subaward to a subrecipient.
In order to comply with the requirements, EHSD must adhere to the following 20 stand-
ards and adequately document all actions taken to comply with the requirements.
EHSD may be required to comply with additional fiscal monitoring requirements above
the 20 standards as required by specific Federal agencies and other pass-through entities.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Pre-award Stage
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
Standard 1
Make a case-by-case determination on whether the contracting
agreement resulting from the RFP or RFI for the disbursement
of federal program funds casts the party receiving the funds in
the role of a subrecipient.
Complete checklist before
issuance of RFP, RFI or
sole source.
Section A Appendix 1
Subrecipi-
ent/ Con-
tractor De-
termination
Checklist
Standard 2
Review the fiscal section of the RFP or RFI to ensure required
budget information and appropriate subrecipient language is in-
cluded in the document.
Review fiscal section be-
fore issuance of RFP or
RFI.
Section A,
Section C
None
Standard 3
Evaluate the risks posed by subrecipient applicants that are re-
sponding to RFP or RFI.
Upon receipt of proposals,
complete risk scoring
sheet during RFI/RFP
evaluation period as re-
quested by Contract Ad-
ministrator.
Section B Scoring
Spreadsheet
Post-award Stage
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
Standard 4
Make a case-by-case determination on whether the contract-
ing agreement for the disbursement of federal program funds
casts the party receiving the funds in the role of a subrecipi-
ent.
Complete checklist annu-
ally before execution of
agreement.
Section A Appendix 1
Subrecipient/
Contractor
Determina-
tion Checklist
Standard 5
Review subrecipient contract budget for reasonableness, allo-
cability and allowability.
Complete checklist annu-
ally before execution of
agreement and when the
subaward is amended.
Section C Appendix 2
Contract
Budget Re-
view Check-
list
Standard 6
Ensure that every subaward is clearly identified to the subre-
cipient as a subaward and includes the required information
at the time of the subaward and if any of these data elements
Include required infor-
mation for each subrecip-
ient before execution of
agreement.
Section D Appendix 3
Special Con-
ditions Tem-
plate
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
change, include the changes in subsequent subaward modifi-
cation.
Standard 7
Gain an understanding of the subrecipient organization, his-
tory of Federal awards, previous audit results, and fiscal prac-
tices.
Send Subrecipient Ques-
tionnaire by July 15th of
each year. Review subre-
cipient response by Au-
gust 30th of each year in
preparation for the com-
pletion of the risk assess-
ment.
Section E Appendix 4
Subrecipient
Questionnaire
Standard 8
Evaluate each subrecipient's risk of noncompliance with Fed-
eral statutes, regulations, and the terms and conditions of the
subaward for purposes of determining the appropriate subre-
cipient monitoring.
Classify subrecipient’s risk level as (1) Low; (2) Moderate;
(3) High
Complete risk assessment
for each subrecipient by
September 30th of each
year.
Section E Appendix 5
Risk Assess-
ment Matrix
Standard 9
Establish fiscal monitoring schedule and monitoring activities
in accordance with subrecipient’s risk level.
Determine if additional monitoring activities are warranted
depending upon EHSD's assessment of risk posed by the sub-
recipient.
By September 30th of
each year.
Section F Appendix 6
Subrecipient
Monitoring
Plan
Standard 10
Monitor the fiscal activities of the subrecipient as necessary
to ensure that the subaward is used for authorized purposes,
in compliance with Federal statutes, regulations, and the
terms and conditions of the subaward.
On-going; on-site moni-
toring and desk review to
begin no later than 60
days after FYE June 30th.
Section F Appendix 7
Monthly De-
mand Review
Guide
Appendix 8
Desk Review
Guide
Appendix 9
On-site Moni-
toring Guide
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
Standard 11
Determine by AL number cumulative Federal subaward pay-
ments for the fiscal year and communicate the amounts to
subrecipient.
Within 30 days of final
settlement, but no later
than September 15th.
Section G Appendix 10
Federal
Subaward
Payment Tem-
plate
Standard 12
Verify that every subrecipient is audited as required by Sub-
part F—Audit Requirements of this part when it is expected
that the subrecipient's Federal awards expended during the re-
spective fiscal year equaled or exceeded the threshold set
forth in §200.501 Audit requirements.
Send prior year single au-
dit certification survey by
November 30th of each
year; Evaluate subrecipi-
ent response by February
15th.
Section H Appendix 11
Single audit
certification
form
Standard 13
Review subrecipient’s single audit to ensure federal pro-
gram(s) funded by EHSD are on the SEFA and identify on
schedules of findings whether there are findings present for
Federal programs.
Complete single audit re-
view checklist within 60
days of due date of single
audit to Federal Audit
Clearinghouse (FAC).
Section I Appendix 12
Single audit
review check-
list
Standard 14
Prepare and issue management decision for single audit find-
ings pertaining to the EHSD’s Federal award provided to the
subrecipient.
Prepare and issue man-
agement decision letter
within 180 days of ac-
ceptance of single audit
by Federal Audit Clear-
inghouse (FAC).
Section J Appendix 13
Management
Decision Tem-
plate
Standard 15
If subrecipient has not completed corrective action(s), pro-
vide a timetable and ensure that subrecipient proceeds with
corrective action(s).
Must be initiated as rap-
idly as possible and cor-
rective action should
begin no later than upon
receipt of the audit report.
Section J Appendix 14
Corrective
Action(s) Let-
ter Template
Standard 16
Consider imposing specific subaward conditions upon a sub-
recipient if appropriate as described in §200.207 Specific
conditions.
On a case-by-case basis if
conditions in section K
are met.
Section K None
Standard 17 On a case-by-case basis if
specific subaward condi-
tions are not adhered to.
Section L None
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
Consider taking enforcement action against noncompliant
subrecipients as described in §200.338 Remedies for non-
compliance of this part and in program regulations.
Standard 18
Assess training needs and prepare an annual schedule to pro-
vide technical assistance for program analysts and subrecipi-
ents. Update training materials as needed.
1st Quarter of each Fiscal
Year
Section M None
Standard 19
Maintain electronic documentation of completed checklists,
reports and communication with subrecipient.
On-going Section M None
Standard 20
Maintain monitoring activities in electronic database.
On-going Section M None
Foster Family Agency (FFA) and Group Home Monitoring and Oversight
Fiscal Monitoring Activities Conducted by Fiscal Staff Action/Timeline References Tools
Verify that every subrecipient is audited as required by Subpart
F—Audit Requirements of this part when it is expected that the
subrecipient's Federal awards expended during the respective fis-
cal year equaled or exceeded the threshold set forth in §200.501
Audit requirements.
Send prior year single au-
dit certification survey by
November 30th of each
year; Evaluate subrecipi-
ent response by February
15th.
Section N Appendix
11
Single au-
dit certifi-
cation
form
Review subrecipient’s single audit to ensure federal program(s)
funded by EHSD are on the SEFA and identify on schedules of
findings whether there are findings present for Federal programs.
Complete single audit re-
view checklist within 60
days of due date of single
audit to Federal Audit
Clearinghouse (FAC).
Section N Appendix
12
Single au-
dit review
checklist
Verify that corrective action(s) have been implemented and/or
ensure that subrecipient proceeds with corrective action(s)
Must be initiated as rap-
idly as possible and cor-
rective action should begin
no later than upon receipt
of the audit report.
Section N Appendix
14
Correc-
tive Ac-
tion(s)
Letter
Template
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
POLICY GUIDANCE AND REFERENCES:
A. Subrecipient/Contractor Determination
EHSD will use the subrecipient/contractor determination checklist to determine if
the contracting relationship with the third-party is of a subrecipient or vendor.
RFP/RFI Issued before July 1, 2016
For contracts for which the Request for Proposal (RFP) or Request for Interest
(RFI) was issued prior to July 1, 2016, EHSD will complete the subrecipient/con-
tractor determination checklist annually before contract execution to ensure the
status remains unchanged from the RFP/RFI subrecipient determination.
RFP/RFI Issued on or after July 1, 2016
For contracts for which the Request for Proposal (RFP) or Request for Interest
(RFI) on July 1, 2016, or thereafter, the determination on whether the contracting
agreement for the disbursement of federal program funds casts the party receiving
the funds in the role of a subrecipient should be made before the issuance of the
RFP or RFI.
Effective July 1, 2016, the RFP or RFI must identify whether the contracting rela-
tionship will be in the form of a subrecipient or contractor (vendor).
EHSD will review the subrecipient/contractor determination annually to ensure
the initial determination status remains unchanged.
Sole Source Contracts
Effective July 1, 2016, for sole source contracts, the subrecipient/contractor deter-
mination will be made annually before contract execution.
The following characteristics are guidelines from 2 CFR 200.331 to assist EHSD
in making the determination of whether a contracting relationship is of subrecipi-
ent or Contractor (vendor).
Subrecipients: A subaward is for the purpose of carrying out a portion of a Federal award and creates a Fed-
eral assistance relationship with the subrecipient. Characteristics which support the classification of the non-
Federal entity as a subrecipient include when the non-Federal entity:
Determines who is eligible to receive what Federal assistance;
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Has its performance measured in relation to whether objectives of a Federal program were met;
Has responsibility for programmatic decision making;
Is responsible for adherence to applicable Federal program requirements specified in the Federal award;
and
In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose
specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-
through entity.
Contractors (vendor): A contract is for the purpose of obtaining goods and services for the non-Federal enti-
ty's own use and creates a procurement relationship with the contractor (vendor). Characteristics indicative of a
procurement relationship between EHSD and a contractor are when the contractor:
Provides the goods and services within normal business operations;
Provides similar goods or services to many different purchasers;
Normally operates in a competitive environment;
Provides goods or services that are ancillary to the operation of the Federal program; and
Is not subject to compliance requirements of the Federal program as a result of the agreement, though
similar requirements may apply for other reasons.
Use of judgment in making determination: In determining whether an agreement between a pass-through en-
tity and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the rela-
tionship is more important than the form of the agreement. All of the characteristics listed above may not be pre-
sent in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or
a procurement contract.
B. Risk-based Approach to Evaluating Risks Posed by Subrecipient Applicant
EHSD is required to evaluate the risks posed by subrecipient applicants that are
responding to RFP or RFI. In evaluating risks posed by subrecipient applicants,
EHSD may use a risk-based approach and may consider information such as the
following:
Financial stability;
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
Quality of management systems and ability to meet the management standards
prescribed in this part;
History of performance. The applicant's record in managing Federal awards, if it
is a prior recipient of Federal awards, including timeliness of compliance with ap-
plicable reporting requirements, conformance to the terms and conditions of pre-
vious Federal awards, and if applicable, the extent to which any previously
awarded amounts will be expended prior to future awards;
Reports and findings from audits performed under Subpart F—Audit Require-
ments of this part or the reports and findings of any other available audits; and
The applicant's ability to effectively implement statutory, regulatory, or other re-
quirements imposed on non-Federal entities.
When a single audit report or any other available audit reports were not performed
on the subrecipient entity, EHSD will request additional information from the
subrecipient entity and apply the above principles to evaluate the risks posed by
the subrecipient applicant.
In addition to this review, EHSD must comply with the guidelines on govern-
ment-wide suspension and debarment in 2 CFR part 180, and must require non-
Federal entities to comply with these provisions. These provisions restrict Federal
awards, subawards and contracts with certain parties that are debarred, suspended
or otherwise excluded from or ineligible for participation in Federal programs or
activities.
EHSD is also required to use a risk-based approach for a subrecipient that has not
been competitively procured (sole source).
C. Incorporation of Subrecipient Language and Evaluation of Subrecipient Budget for
Reasonableness, Allocability and Allowability
Effective July 1, 2016, the subrecipient determination is required to be made be-
fore the RFP or RFI publication. When entity is classified as a subrecipient, the
RFP or RFI should be reviewed for inclusion of appropriate subrecipient language
subject to federal CFRs and Single audit requirements.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
The subrecipient entity receiving Federal funds is required to provide detailed
budget information to assist EHSD with evaluating the reasonableness, allocabil-
ity and allowability of the proposed costs to operate the program.
The budget evaluation is one of many aspects of the fiscal subrecipient monitor-
ing program. The fundamental guiding principles for an effective budget evalua-
tion of a subrecipient that is required to comply with Federal cost principles de-
scribed in 2 CFR 200 Subpart D (for HHS subawards, 45 CFR 75 Subpart E) are
as follows:
The subrecipient is responsible for the efficient and effective administration of the
Federal award through the application of sound management practices.
The subrecipient assumes responsibility for administering Federal funds in a man-
ner consistent with underlying agreements, program objectives, and the terms and
conditions of the Federal award.
The subrecipient, in recognition of its own unique combination of staff, facilities,
and experience, has the primary responsibility for employing whatever form of
sound organization and management techniques may be necessary in order to as-
sure proper and efficient administration of the Federal award.
The application of these cost principles should require no significant changes in
the internal accounting policies and practices of the subrecipient. However, the
accounting practices of the subrecipient must be consistent with these cost princi-
ples and support the accumulation of costs as required by the principles, and must
provide for adequate documentation to support costs charged to the Federal
award.
In reviewing, negotiating and approving cost allocation plans or indirect cost pro-
posals, the cognizant agency for indirect costs should generally assure that the
subrecipient is applying these cost accounting principles on a consistent basis dur-
ing their review and negotiation of indirect cost proposals. Where wide variations
exist in the treatment of a given cost item by the subrecipient, the reasonableness
and equity of such treatments should be fully considered.
The subrecipient may not earn or keep any profit resulting from Federal financial
assistance, unless explicitly authorized by the terms and conditions of the Federal
award. Commercial organizations subject to FAR may earn a profit if not prohib-
ited by the applicable CFR or terms and conditions of the Federal award. Note:
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Prohibition on profit earning by commercial entity determined to be a subrecipi-
ent is present in 45 CFR 75.216.
Cost reasonableness principles: A cost is reasonable if, in its nature and amount,
it does not exceed that which would be incurred by a prudent person under the cir-
cumstances prevailing at the time the decision was made to incur the cost. In de-
termining reasonableness of a given cost, consideration must be given to:
Whether the cost is of a type generally recognized as ordinary and necessary for
the operation of the subrecipient or the proper and efficient performance of the
Federal award.
The restraints or requirements imposed by such factors as: sound business prac-
tices; arm's-length bargaining; Federal, state, local, and other laws and regula-
tions; and terms and conditions of the Federal award.
Market prices for comparable goods or services for the geographic area.
Whether the individuals concerned acted with prudence in the circumstances con-
sidering their responsibilities to the subrecipient, its employees, the public at
large, and the Federal Government.
Whether the subrecipient significantly deviates from its established practices and
policies regarding the incurrence of costs, which may unjustifiably increase the
Federal award's cost.
Factors impacting the allowability of costs: Except where otherwise authorized
by statute, costs must meet the following general criteria in order to be allowable
under Federal awards:
Be necessary and reasonable for the performance of the Federal award and be
allocable thereto under these principles.
Conform to any limitations or exclusions set forth in these principles or in the
Federal award as to types or amount of cost items.
Be consistent with policies and procedures that apply uniformly to both federally-
financed and other activities of the subrecipient.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Be accorded consistent treatment. A cost may not be assigned to a Federal award
as a direct cost if any other cost incurred for the same purpose in like circum-
stances has been allocated to the Federal award as an indirect cost.
Be determined in accordance with generally accepted accounting principles
(GAAP).
Not be included as a cost or used to meet cost sharing or matching requirements
of any other federally-financed program in either the current or a prior period.
Be adequately documented.
The above principles must be used in determining the reasonableness, allowability
and allocability of costs for work performed by the subrecipient under Federal
awards. For specific rules, review 2 CFR 200 Subpart D (for HHS subawards, 45
CFR 75 Subpart E).
These principles also must be used by the EHSD as a guide in the pricing of
fixed-price contracts and subcontracts where costs are used in determining the ap-
propriate price (sole source vendor when a competitive market for the procured
service/good does not exist). The principles do not apply to fixed amounts based
on such items as education allowance or published tuition rates and fees.
D. Required Information in Subaward
When the contracting relationship is determined to be of a subrecipient, the legal
instrument is referred to as a subaward in 2 CFR 200.92. EHSD is to include the
following required information in each subaward (2 CFR 200.331 and for HHS
subaward 45 CFR 75.352), unless otherwise authorized in applicable CFR:
1. Federal Award Identification
a. Subrecipient name (which must match the name associated with its
unique entity identifier);
b. Subrecipient's unique entity identifier 1;
1 SAM.gov, an official website of the U.S. government announced on their website the unique entity identifier used in SAM.gov has
changed effective April 4, 2022.
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
c. Federal Award Identification Number (FAIN), if applicable;
d. Federal Award Date, if applicable;
e. Subaward Period of Performance Start and End Date;
f. Amount of Federal Funds Obligated by this action;
g. Total amount of Federal Funds Obligated to the subrecipient in the
Federal subaward;
h. Name of pass-through entity,
i. AL Number and Name; the pass-through entity must identify the
dollar amount made available under each Federal award and the
AL number at time of disbursement; and
j. Subrecipient’s federally approved indirect cost rate agreement.
When some of above information is not available, EHSD must provide the best
information available to describe the Federal award and subaward.
2. All requirements imposed by the pass-through entity on the subrecipient
so that the Federal award is used in accordance with Federal statutes, regu-
lations and the terms and conditions of the Federal award.
3. Any additional requirements that the pass-through entity imposes on the
subrecipient in order for the pass-through entity to meet its own responsi-
bility to the Federal awarding agency including identification of any re-
quired financial and performance reports;
4. A requirement that the subrecipient permit the pass-through entity and au-
ditors to have access to the subrecipient's records and financial statements
as necessary for the pass-through entity to meet the requirements of this
part; and
5. Appropriate terms and conditions concerning closeout of the subaward.
6. Effective April 4, 2022, the unique entity identifier used across the federal
government changed from the DUNS Number to the Unique Entity ID
(UEI) generated by SAM.gov.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Existing registered entities (subrecipients/subcontractors) can find their
UEI as follows:
a. Log in to SAM.gov.
b. Select “Search” from the header menu.
c. Expand “Select Domain,” then select “Entity Information,” then
“Entities.”
d. You can then use keywords and filters to search for the entity you
are trying to locate. The UEI is displayed in the search results for
each entity.
New entities (subrecipients/subcontractors) can get their UEI at SAM.gov
and, if required, complete an entity registration.
Effective fiscal year FY 2022-2023, all EHSD’s subcontractors/subrecipi-
ents receiving federal funds, will be sent a letter informing them of this
change including the steps described above to obtain the new UEI. The
contractor will have 10 business days to provide their UEI to EHSD Con-
tracts and Grants Division.
All new subcontractors/subrecipients will be required to get their UEI at
SAM.gov and provide EHSD with the number before the subaward is
awarded to the subrecipient in response to a RFP or RFI.
If the contractor does not comply, the EHSD Contracts and Grants Divi-
sion will follow-up with the contractor.
E. Evaluation Factors to Assess Subrecipient’s Risk of Noncompliance
EHSD Contract Unit will verify and track all contractors UEI at the early stage of
the contract development and prior to awarding a contract.
• Upon receipt of the UEI number, the Contract Analyst will log into
SAM.gov website.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
• Contract Analyst will conduct a clearance and check the Excluded Parties
List System (EPLS) to verify the contractor account is active and in good
standing.
• If contractor’s account is not in good standing, the Department will add
such contractor in the Excluded Parties List System (EPLS) and will not
be able to execute a contract.
• A print-out of the clearance will be saved electronically.
EHSD will require each of its subrecipients to complete the Subrecipient Question-
naire annually to gain an understanding of the subrecipient organization, history of
Federal awards, previous audit results, and fiscal practices.
EHSD must evaluate each subrecipient's risk of noncompliance with Federal stat-
utes, regulations, and the terms and conditions of the subaward for purposes of de-
termining the appropriate subrecipient monitoring. The evaluation may include
consideration of such factors as those listed below:
1. The subrecipient's prior experience with the same or similar subawards;
2. The results of previous audits including whether or not the subrecipient
receives a Single Audit in accordance with Subpart F—Audit Require-
ments of this part, and the extent to which the same or similar subaward
has been audited as a major program;
3. Whether the subrecipient has new personnel or new or substantially
changed systems; and
4. The extent and results of Federal awarding agency monitoring (e.g., if the
subrecipient also receives Federal awards directly from a Federal award-
ing agency).
EHSD will use the information from the responses to the Annual Subrecipient
Questionnaire and other pertinent information to determine the subrecipient’s
level of risk by completing the risk assessment matrix. Each subrecipient will be
attributed a level of risk (Low, Moderate and High) based on a multiplicity of fac-
tors outlined in the risk assessment matrix.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
F. Monitoring of Subrecipient Fiscal Activities
EHSD will monitor the fiscal activities of the subrecipient as necessary to ensure
that the subaward is used for authorized purposes, in compliance with Federal
statutes, regulations, and the terms and conditions of the subaward. The monitor-
ing activities must include at least:
1. Reviewing financial reports required by EHSD.
2. Following-up and ensuring that the subrecipient takes timely and appropri-
ate action on all deficiencies pertaining to the Federal award provided to
the subrecipient from EHSD detected through audits, on-site reviews, and
other means.
3. Issuing a management decision for audit findings pertaining to the Federal
award provided to the subrecipient from EHSD as required by §200.521
Management decision.
4. Depending upon EHSD's assessment of risk posed by the subrecipient, the
following monitoring tools may be useful for EHSD to ensure proper ac-
countability of the Federal award:
5. Providing subrecipients with training and technical assistance on fiscal-
related matters;
6. Performing on-site reviews or desk review of the subrecipient's fiscal op-
erations;
7. Arranging for agreed-upon-procedures engagements as described in
§200.425 Audit services. EHSD may charge Federal awards for the cost of
agreed-upon-procedures engagements to monitor a subrecipient that are
exempted from the requirements of the Single Audit Act and Subpart F—
Audit Requirements of this part. This cost is allowable only if the agreed-
upon-procedures engagements are meeting the requirements in §200.425
(c)(1), (c)(2) and (c)(3).
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Risk(s)
Level
Monitoring Activities Who Frequency
Low,
Moderate
and High
Send prior year single audit certi-
fication survey to each subrecipi-
ent
Fiscal Analyst Annually
Low,
Moderate
and High
Review single audit for findings
and accuracy of SEFA
Fiscal Analyst Annually if sub-
recipient is sub-
ject to single au-
dit
Low,
Moderate
and High
Review audited financial state-
ments to assess financial stabil-
ity.
Review auditor’s opinion and in-
ternal control report
Fiscal Analyst Annually if sub-
recipient is sub-
ject to single au-
dit or if financial
statements audit
available only
Low,
Moderate
and High
Review responses to Subrecipi-
ent Questionnaire
Fiscal Analyst Annually
Low,
Moderate
and High
Review monthly financial reports
(demands) for each subrecipient
Program Analyst
Account Clerk
Fiscal Analyst, if issue
is unresolved or open
findings
Monthly
Low Conduct desk review if subrecip-
ient is not subject to Single Audit
requirement and risk level is as-
sessed at Low
Fiscal Analyst Annually if sub-
recipient is not
subject to single
audit
Moderate
and High
Conduct on-site monitoring if
subrecipient is not subject to Sin-
gle Audit requirement and risk
level is assessed at Moderate or
High.
Fiscal Analyst Annually if sub-
recipient is not
subject to single
audit
Moderate Conduct desk review if subrecip-
ient is subject to Single Audit and
Fiscal Analyst Annually
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Risk(s)
Level
Monitoring Activities Who Frequency
no prior findings from Single Au-
dit or EHSD’s monitoring,
High Conduct on-site monitoring visit Fiscal Analyst Annually
G. Report on Cumulative Federal Subaward Payments to Subrecipient
EHSD is required to report to its subrecipients their cumulative Federal subaward
payments by AL number within 30 days of the final settlement, but no later than
September 15th of each year.
H. Subrecipient Subject to Single Audit Requirements
EHSD will verify that every subrecipient is audited as required by Subpart F—
Audit Requirements of 2 CFR 200 when it is expected that the subrecipient's Fed-
eral awards expended during the respective fiscal year equals or exceeds the
threshold set forth in §200.501 Audit requirements.
EHSD will send a single audit certification survey to its subrecipients by Novem-
ber 30th of each year and require a response within 30 days of the date of the let-
ter. A review of the survey responses will be performed to determine which subre-
cipients are subject to the single audit requirement and when the single audit is
expected to be filed with FAC.
Responses to the single audit survey will be logged in a database for ease of track-
ing. EHSD will follow up on subrecipients that have not responded to the single
audit survey or have not sent their single audit report by the FAC filing date.
In addition to those subrecipients undergoing periodic monitoring will be those
chosen for special monitoring. Special monitoring will focus on subrecipients
EHSD has reason to believe that federal funds are not being expended appropri-
ately or that the subrecipient is concerned about its compliance status and re-
quests a monitoring visit.
Sub-recipients and programs can be selected for special monitoring at the discre-
tion of the EHSD Chief Financial Officer or the EHSD Director.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
I. Review of Subrecipient Single Audit
Upon determining that a subrecipient is subject to the single audit requirements,
EHSD will track whether the single audit reports are received by the FAC filing
date.
EHSD will review the subrecipient single audit to ensure that federal program(s)
funded by EHSD are on the SEFA and identify on schedules of findings whether
there are findings present for EHSD’s federal programs. The results of the review
will be logged in the database and, if necessary, EHSD will issue a management
decision and/or require the subrecipient to issue a corrective action plan as de-
scribed in section J below.
J. Issuance of Management Decision and Subrecipient Corrective Actions
If audit findings are present, EHSD must issue a management decision that clearly
states whether or not the audit finding is sustained, the reasons for the decision,
and the expected auditee action to repay disallowed costs, make financial adjust-
ments, or take other action.
EHSD will also provide a timetable to the subrecipient if the entity has not com-
pleted its corrective action plan.
Prior to issuing the management decision, EHSD may request additional infor-
mation or documentation from the auditee, including a request for auditor assur-
ances related to the documentation, as a way of mitigating disallowed costs.
The management decision should describe the, if any, appeal process available to
the subrecipient.
EHSD must issue a management decision within six months of acceptance of the
audit report by the Federal Audit Clearinghouse (FAC). The subrecipient (audi-
tee) must initiate and proceed with corrective action as rapidly as possible and
corrective action should begin no later than upon receipt of the audit report.
While not required by §200.521, EHSD may also issue a management decision on
findings relating to the financial statements.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
K. Additional Specific Award Conditions upon a Subrecipient as Appropriate
EHSD may impose additional specific award conditions as needed under the fol-
lowing circumstances:
Based on the criteria set forth in EHSD’s review of risk posed by applicants;
When an applicant or subrecipient has a history of failure to comply with the
general or specific terms and conditions of a Federal award;
When an applicant or subrecipient fails to meet expected performance goals
as described in §200.210 Information contained in a Federal award; or
When an applicant or subrecipient is not otherwise responsible.
Additional federal award conditions may include items such as the following:
Requiring payments as reimbursements rather than advance payments;
Withholding authority to proceed to the next phase until receipt of evidence of
acceptable performance within a given period of performance;
Requiring additional, more detailed financial reports;
Requiring additional project monitoring;
Requiring the non-Federal entity to obtain technical or management assis-
tance; or
Establishing additional prior approvals.
EHSD must notify the applicant or subrecipient regarding:
The nature of the additional requirements;
The reason why the additional requirements are being imposed;
The nature of the action needed to remove the additional requirement, if appli-
cable;
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
The time allowed for completing the actions if applicable, and
The method for requesting reconsideration of the additional requirements im-
posed.
EHSD must promptly remove any specific conditions once the conditions that
prompted them have been corrected.
L. Remedies for Noncompliance of 2 CFR 200 and in Program Regulations
EHSD may take one or more of the following actions, as appropriate to the cir-
cumstances, if it is determined that the subrecipient noncompliance cannot be
remedied by imposing additional conditions:
Temporarily withhold cash payments pending correction of the deficiency by
the subrecipient or more severe enforcement action EHSD.
Disallow (that is, deny both use of funds and any applicable matching credit
for) all or part of the cost of the activity or action not in compliance.
Wholly or partly suspend or terminate the subaward.
Recommend to the Federal awarding agency the initiation of suspension or
debarment proceedings as authorized under 2 CFR part 180 and Federal
awarding agency regulations.
Withhold further Federal awards for the project or program.
Take other remedies that may be legally available.
M. Subrecipient Monitoring Standards and Tracking Subrecipient Monitoring Activities
Section VI. Policy and Standards for Fiscal Monitoring of this document estab-
lishes the monitoring standards, frequencies of activities, reference materials, and
tools that the Fiscal staff are responsible for implementing annually under the di-
rection of the Fiscal Officer.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
N. Foster Family Agency (FFA) and Group Home Monitoring and Oversight
Pursuant to guidance received in 2001 from the federal Administration for Children
and Families (ACF), Foster Care providers who operate group homes and/or FFA
programs that receive an Aid to Families with Dependent Children-Foster Care pro-
gram rate are considered subrecipients and are subject to the same audit require-
ments and require the same degree of oversight as other subrecipients.
Although EHSD can reasonably rely on the findings of Single audits required by
California Department of Social Services (CDSS) and management letters issued
accordingly, EHSD will review those audits and their findings and follow up to
ensure compliance and monitoring and oversight required by federal and state
laws and regulations. (County Fiscal Letter No. 15/16-62)
O. Fiscal Monitoring in the Aging and Adult Bureau
The designated fiscal staff will follow policy standards with the exception to
Standard 9. Regardless of the risk level, Monitoring Plan #3 must be followed at
minimum every other year.
P. Fiscal Monitoring in the Workforce Development Board Bureau
The designated fiscal staff will follow policy standards with the exception to
Standard 9. Regardless of the risk level, Monitoring Plan #3 must be followed
every year.
Q. Fiscal Monitoring and Head Start/Early Head Start Regulations on the Allowabil-
ity of Costs and Inventory Requirements in the Community Service Bureau
The designated fiscal staff will follow policy standards with the exception to
Standard 9. Regardless of the risk level, Delegate Monitoring Plan #4 must be
followed. For all other subrecipients, Monitoring Plan #3 will be followed.
Self-Monitoring – Appendix 15
As a recipient of federal and state awards, EHSD is responsible for establishing a
self-monitoring policy per 45 CFR Part 75.303(c). Initial monitoring will take
place quarterly and semi-annually thereafter. Compliance assessments will be
conducted to ensure:
• Compliance with statutory requirements
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
• Review of internal checks/controls
• Review of financial documents
• Review of business practices, processes and policies
Internal Controls – 45 CFR Part 75.303
The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and condi-
tions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government,” issued
by the Comptroller General of the United States or the “Internal Control Inte-
grated Framework,” issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
(b) Comply with Federal statutes, regulations, and the terms and conditions of the
Federal awards.
(c) Evaluate and monitor the non-Federal entity's compliance with statutes, regu-
lations and the terms and conditions of Federal awards.
(d) Take prompt action when instances of noncompliance are identified including
noncompliance identified in audit findings.
(e) Take reasonable measures to safeguard protected personally identifiable infor-
mation and other information the HHS awarding agency or pass-through entity
designates as sensitive or the non-Federal entity considers sensitive consistent
with applicable Federal, state, local, and tribal laws regarding privacy and obliga-
tions of confidentiality.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Pursuant to Head Start Performance Standard – 1302.102(b) Achieving program
goals:
Monitoring program performance. (1) Ongoing compliance oversight and correc-
tion. In order to ensure effective ongoing oversight and correction, a program
must establish and implement a system of ongoing oversight that ensures effective
implementation of the program performance standards, including ensuring child
safety, and other applicable federal regulations as described in this part, and must:
(i) Collect and use data to inform this process;
(ii) Correct quality and compliance issues immediately, or as quickly as possible;
(iii) Work with the governing body and the policy council to address issues during
the ongoing oversight and correction process and during federal oversight; and,
(iv) Implement procedures that prevent recurrence of previous quality and compli-
ance issues, including previously identified deficiencies, safety incidents, and au-
dit findings.
CSB Fiscal Process – Head Start and Early Head Start
Employment and Human Services Department (EHSD) charges costs that are rea-
sonable, allowable, and allocable to a federal award directly or indirectly. All un-
allowable costs shall be appropriately segregated from allowable costs in the gen-
eral ledger in order to assure that unallowable costs are not charged to federal
awards. (See Appendix 16)
Delegate Onsite Monitoring Tool – Appendix 17
ROLES, RESPONSIBILITIES AND DATA MANAGEMENT
Under the direction of the Fiscal Officer, the Social Services Compliance Accountant
(SSCA) is responsible for establishing EHSD’s fiscal monitoring framework and imple-
menting systems that track the actual monitoring activities against the established moni-
toring standards, frequencies of activities, reference materials, and tools. The SSCA will
also oversee the updates to the fiscal monitoring policy, reference materials and tools.
The SSCA is responsible for creating and maintaining technical assistance materials to
assist the Fiscal staff with educating subrecipients and program analysts on the monitor-
ing standards, frequencies of activities, reference materials, and tools. The SSCA will
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Contra Costa County Issued/Revised 05-10-2023
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also prepare an annual schedule of technical assistance sessions for the Fiscal staff, Pro-
gram Analysts and Subrecipient, and ensure that technical assistance sessions are con-
ducted annually according to schedule.
During the peak monitoring periods, the Fiscal Officer will direct accounting and admin-
istrative support whenever possible to assist the Fiscal staff and SSCA with implementing
the monitoring standards established in this policy document.
The next section describes the tracking of data and forms related to monitoring activities.
Pre-award Stage:
The SSCA will obtain RFP or RFI schedule from the Contract administrator and coordi-
nate the pre-award activities with the designated Fiscal staff.
The SSCA will maintain an electronic data table containing basic information on RFP or
RFI as follows:
Table 1: Pre-award Subrecipient Tracking
Fiscal Analyst Name
Bureau
RFP or RFI Number
RFP or RFI PDF
Start RFP or RFI Date
End RFP or RFI Date
Federal funds (Y/N)
Subrecipient Checklist due
Subrecipient Determination
(Y/N)
# of Proposals Received
The designated Fiscal staff will identify whether the contracted services will be funded
with Federal funds and complete the subrecipient determination checklist as appropriate.
The checklist will be stored electronically and the information provided to SSCA.
For each RFP or RFI contracting instrument identified as subaward, the SSCA will main-
tain an electronic data table containing information on RFP or RFI respondents as fol-
lows:
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Table 2: Pre-award Fiscal Scores
RFP or RFI Number
Proposal #?
Legal Entity Name
Score
Total Score
The designated Fiscal staff will evaluate the risk posed by subrecipient applicants who
are responding to the RFP or RFI. Thee checklist will be stored electronically and the
score information provided to SSCA and the designated staff in the contracts unit.
Post-award Stage
The SSCA will maintain an electronic data table containing basic information on each
subrecipient and contractor (vendor) as follows:
Table 3: Post-award Basic Contract Data
Contract Number
Contract PDF
Start Contract Date
End Contract Date
Federal funds (Y/N)
Subrecipient Checklist
Due
Subrecipient (Y/N)
Special Conditions (Y/N)
Legal Entity Name
Legal Entity Type
Mailing address
Mailing City
Mailing State
Fiscal Contact Last Name
Fiscal Contact First Name
Fiscal Contact Title
Fiscal Contact Position
Telephone number
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Email
Fiscal Analyst Name
Bureau
The designated Fiscal staff will maintain in a centralized location electronic copies of the
contract and completed subrecipient determination checklist.
The SSCA will maintain an annual electronic data table containing basic information on
each subrecipient identified in Table 3 as follows:
Table 4: Post-award Subrecipient Monitoring Activities
Vendor Number
AL
Federal funds Expended at year-end for each AL #
($)
Letter with Federal funds expended by AL # mailed
(Y/N)
Awarding Agency
Program Name
Legal Entity Type
Budget Review Completed (Y/N)
Subrecipient Contract language (Y/N)
Subrecipient Questionnaire Sent (Y/N)
Subrecipient Questionnaire Received (MM/DD/YY)
Risk Assessment Matrix (Y/N)
Risk Level (L/M/H)
Review Invoices Required (Y/N)
Desk Review Required (Y/N)
On-site Visit Required (Y/N)
Monitoring Date Scheduled on (MM/DD/YY)
Desk or On-site Monitoring Completed (NA/Y/N)
Monitoring Report Issued (Y/N)
Finding(s) Y/N
Observation(s) Y/N
Contractor Response Required (Y/N)
Response Received (NA/Y/N)
Response Adequate (Y/N)
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
The designated Fiscal staff will provide the information identified in Table 4 for each
subrecipient to the SSCA. Federal funds expended by AL number will be provided to the
SSCA within 30 days of final settlement, but no later than September 15th. The SSCA
will consolidate the monitoring activities into the EHSD annual monitoring plan by Octo-
ber 15th of each year.
The designated Fiscal staff will store the following electronic documents for each subre-
cipient in a centralized location:
Review of subrecipient budget for reasonableness, allowability and allocability
Subrecipient’s responses to Subrecipient Questionnaire
Risk Assessment matrix
Subrecipient monitoring plan
Desk review or on-site visit monitoring tool
Monitoring report
Response from subrecipient and corrective action plan, if applicable
Letter with Federal funds expended mailed to subrecipient
The SSCA will maintain an annual electronic data table containing basic information on
each subrecipient identified in Table 3 as follows:
Table 5: Post-award Subrecipient Single Audit Review
Vendor Number
Sent Request for Single Audit Certification (Y/N)
Method Certification Requested (Mail/Email)
Due Date for Certification (MM/DD/YY)
Received Certification (Y/N)
If Certification Not Received, Follow-up Action (Y/N)
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
Over $750,000 (Y/N)
Estimated date for Single Audit (MM/DD/YY)
If Single Audit Not Received, Follow-up Action (Y/N)
Date Single Audit Reviewed by Analyst (MM/DD/YY)
Unmodified Opinion on Audited Financial Statements (Y/N)
Unmodified Opinion on Compliance of Major Federal Programs
(Y/N)
Auditee Identified as High Risk (Y/N)
Finding(s) Reported in Single Audit: (Y/N)
If Finding(s) Reported, Management Letter Due Date
(MM/DD/YY)
If Finding(s) Reported, Letter to Subrecipient Regarding Cor-
rective Action (Y/N)
If Finding(s) Reported, Letter to Subrecipient Regarding Ques-
tioned Cost (Y/N)
Subrecipient Response Received (MM/DD/YY)
Subrecipient Exercising Appeal Rights (Y/N)
The designated Fiscal staff will provide the information in Table 5 for each subrecipient
to the SSCA.
The designated Fiscal staff will maintain in a centralized location electronic copies of the
following documents for each subrecipient:
Single audit survey completed by subrecipient
Subrecipient single audit
Subrecipient checklist
Management letter to subrecipient, if applicable
Subrecipient response to management letter
Subrecipient request to appeal questioned cost in management letter
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 1
APPENDIX 1: SUBRECIPIENT/CONTRACTOR DETERMINATION CHECKLIST
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 1
Legal Entity Name: Contract Number: For FY 20
AL Number: Program Name:
Subrecipient/Contractor Determination Checklist
(Only use this checklist if legal instrument is funded with Federal dollars)
INSTRUCTIONS:
Begin by evaluating whether one or more characteristics listed under Section 1 – Subrecipient apply to the scope of work included in the legal
instrument under review. If none of the Section 1 – Subrecipient characteristic applies, confirm that the relationship between EHSD and the 3rd
party is of a contractor (vendor) by evaluating whether one or more characteristics listed under Section 2 – Contractor (vendor) apply.
When the subrecipient or contractor relationship is unclear, the Analyst will use his/her best judgment in making the subrecipient or contractor
determination. Due diligence in making the determination may include past experience with similar legal instruments, reviewing prior EHSD or
other Counties subrecipient determination findings, consulting with other Fiscal Analysts, and requesting technical assistance from the funding
entity. The comment section should be used to provide justification when subrecipient or contractor relationship requires further clarifications.
In determining whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient or a contrac-
tor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be
present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract.
SECTION 1 – SUBRECIPIENT
Description: A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the
subrecipient. Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:
1. Determines who is eligible to receive what Federal assistance;
2. Has its performance measured in relation to whether objectives of a Federal program were met;
3. Has responsibility for programmatic decision making;
4. Is responsible for adherence to applicable Federal program requirements specified in the Federal award;
5. In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in
authorizing statue, as opposed to providing goods or services for the benefit of the pass-through entity.
SECTION 2– CONTRACTOR (vendor)
Description: A contract is for the purpose of obtaining goods and services for the non-Federal entity’s own use and creates a procurement rela-
tionship with the contractor. Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when
the non-Federal entity receiving the Federal funds:
1. Provides the goods and services within normal business operations;
2. Provides similar goods or services to many different purchasers;
3. Normally operates in a competitive environment;
4. Provides goods or services that are ancillary to the operation of the Federal program.
5. Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar re-
quirements may apply for other reasons.
Comment
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 1
DETERMINATION:
SUBRECIPIENT CONTRACTOR
Analyst Name: Date:
DEFINITIONS FROM Uniform Guidance (2 CFR, Part 200)
Subrecipient (§200.93)
Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of
such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.
Contractor (§200.23)
Contractor means an entity that receives a contract as defined in §200.22 Contract. §200.22 Contract means a legal instrument by which a non-Federal entity purchases property or services
needed to carry out the project or program under a Federal award.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 2
APPENDIX 2: CONTRACT BUDGET REVIEW CHECKLIST
DEPARTMENTAL FISCAL
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 2
Checklist to Review Budgeted Costs for Allowability, Allocability and Reasonableness
This Checklist is intended to assist Fiscal Analysts with reviewing the subrecipient budget submitted to EHSD, and making a de-
termination on whether budgeted costs are allowable, allocable and reasonable to operate the program.
Contract Number:
Subrecipient Name:
Prepared by: Date:
References:
• Title 2 - Code of Federal Regulations, Part 200, Grants and Agreements;
• Title 45 - Code of Federal Regulations, Public Welfare;
• Title 29 - Code of Federal Regulations, Labor;
• Federal Acquisition Regulations (FAR) Part 31, Cost Principles and Procedures for Commercial Entities;
• Federal Acquisition Regulations (FAR) Part 48, Cost Accounting Standards for Commercial Entities; and
• Other applicable Title(s) as indicated in grant agreement(s).
We strongly encourage the reader to review the applicability and exceptions sections found in 2 CFR 200.101 and 2 CFR 200.102 when making a
determination on the applicability of the various CFR rules.
Determination Factors Yes √ No √
1. Are the budgeted costs necessary and reasonable?
2. Are the budgeted costs allocable to the Federal subaward?
3. Are the budgeted costs allowable to the Federal subaward?
4. Was there a cost allocation plan or description of the cost allocation methodology submitted if com-
mon costs such as rent are allocated to the Federal?
5. If a cost allocation plan or description of the cost allocation methodology was submitted, is the
methodology to distribute common cost reasonable?
6. If there is a budgeted indirect cost rate:
a. Was a Federally approved indirect rate submitted?
b. Did the entity include an indirect cost using the de minimis rate?
7. Was sufficient information provided to determine whether costs are correctly allocated to each
budget category (for example: Personnel cost vs Participant cost)?
8. Do line items add up correctly?
9. Were budget calculations verified for accuracy?
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 2
10.Is there a budget narrative included?
Comment:
Consider increasing the level of risk for the subrecipient as necessary based on your assessment of the cost reasonableness, allocability
and allowability.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 3
APPENDIX 3: SPECIAL CONDITIONS TEMPLATE
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EFFECTIVE: 05-10-2023
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 3
Contra Costa County SPECIAL CONDITIONS Number xx-xxx-x
Special Conditions Form Federal Subaward Conditions
I. The contract meets the conditions of a Federal subaward and the Contractor is
subject to the Subrecipient provisions in 2 CFR or 45 CFR Part 75.
II. Definitions:
A. CFR means Code of Federal Regulations
B. Assistance Listings (AL) (formerly Catalog of Federal Domestic Assis-
tance (CFDA))
C. Subrecipient – – Title 2 CFR section 200.93 or 45 CFR Part 75.2
Subrecipient means a non‐Federal entity that receives a subaward from a
pass‐through entity to carry out part of a Federal program; but does not in-
clude an individual that is a beneficiary of such program. A subrecipient
may also be a recipient of other Federal awards directly from a Federal
awarding agency.
D. Subaward – – Title 2 CFR section 200.92 or 45 CFR Part 75.2
Subaward means an award provided by a pass‐through entity to a subrecip-
ient for the subrecipient to carry out part of a Federal award received by
the pass‐through entity. It does not include payments to a contractor or
payments to an individual that is a beneficiary of a Federal program. A
subaward may be provided through any form of legal agreement, including
an agreement that the pass‐through entity considers a contract.
E. Pass-through Entity – – Title 2 CFR section 200.74 or 45 CFR Part 75.352
Pass-through entity means a non-Federal entity that provides a subaward
to a subrecipient to carry out part of a Federal program.
III. The pass-through entity is the County of Contra Costa.
IV. The Subrecipient is Fill in contractor name.
V. The Subrecipient’s unique identification number is Fill In.
VI. If applicable, the Federal Award Date is Fill in or not applicable.
VII. If applicable, the Federal Award Identification Number (FAIN) is Fill in or not
applicable.
VIII. The Subaward Period of Performance is from Fill in Start Date to Fill in End
Date.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 3
IX. The total amount of Federal Funds Obligated to the subrecipient in this Federal
subaward award is: Fill In.
X. The AL Number is Fill In.
XI. The Federal Program Title is Fill In.
XII. The Subrecipient’s federally approved indirect cost rate agreement is incorporated
by reference if the Subrecipient’s budget submitted includes a federally approved
indirect cost.
XIII. The Subrecipient shall use the Federal award in accordance with Federal statutes,
regulations and the terms and conditions of the Federal award.
Revised 2016 Initials: __________ __________ Contractor County Dept.
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EFFECTIVE: 05-10-2023
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
APPENDIX 4: SUBRECIPIENT QUESTIONNAIRE
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EFFECTIVE: 05-10-2023
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
Subrecipient Questionnaire
Please complete the following questionnaire and fax to (925) or email to:
___________@ehsd.cccounty.us by____________. Feel free to add pages with explanations.
You may provide copies of your policies and procedures.
Legal Name:
Fictitious Business Name:
Type of Legal Ownership :
Address:
City:
Agency Fiscal Contact:
Telephone Number:
Fax Number:
Email Address:
Website Address:
Executive Director’s Name: Fiscal Year:
1. How long has your organization been in business?
2. Please provide your organization’s chart, if available. Has your organization recently experi-
enced changes in senior management?
Yes No
If yes, please provide a brief description of the change(s).
3. Please provide your organization’s fiscal org chart, if available with a brief description of
your organization’s fiscal org structure and the average number of years your key fiscal staff
have worked for your organization.
4. Is your organization currently in a litigation(s) that could adversely impact on your organiza-
tion’s ability to perform on the EHSD contract(s) or place your organization out of compli-
ance with Federal, State or Local laws?
Yes No
If yes, please describe.
5. Have you previously entered into one or more agreements funded with Federal award(s) to
perform the same or similar work as the scope of work included in the current EHSD agree-
ment?
Yes No
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
If yes, please list current year agreements and those received in the past three years and indi-
cate whether your organization received each Federal award directly from the US Federal
Government or a pass-through entity.
For each of the agreements you received, indicate whether there were one or more findings in
your organization’s single audit or monitoring report issued by the funding entity.
Awarding Agency:
Award Period:
Type of work performed
Audit/Monitoring Finding (s):
Awarding Agency:
Award Period:
Type of work performed
Audit/Monitoring Finding (s):
Awarding Agency:
Award Period:
Type of work performed
Audit/Monitoring Finding (s):
6. In the previous three years and during current year have you entered into one or more agree-
ments funded with Federal award(s) to perform work unrelated to the scope of work included
in the current EHSD agreement?
Yes No
If yes, please provide a brief description of the work performed under the agreement(s) and
the funding agency name. Please provide a list of Audit/Monitoring findings, if any.
7. Is your organization subject to the Single Audit requirements as described in 2 CFR 200
Subpart F and 45 CFR 75.501?
Yes No
Date of Last Single Audit:
Fiscal Period Audited:
Audit Firm:
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EFFECTIVE: 05-10-2023
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
Auditor’s Opinion on Financial Statements Unqualified: Yes No
If not, State Reason:
Auditor’s Opinion on Compliance for Major Program(s) Unqualified: Yes No
If not, State Reason:
Auditor’s Determination on Auditee’s Risk Level: (Circle) High Risk Low Risk
Does your organization’s Single Audit disclose findings? Yes No
If yes, are the findings resolved (closed)? Yes No
If the findings are not closed, what is the status of you corrective action plan?
Enclosed is a copy of the audit report and management letter package (pdf copy preferred.)
8. If your organization is not subject to the Single Audit requirements, do you have annual fi-
nancial statements that have been compiled, reviewed or audited by an independent audit
firm?
Yes No
If yes:
Date of Last Financial Statement Audit:
Fiscal Period Audited:
Audit Firm:
Auditor’s Opinion on Financial Statements Unqualified: Yes No
If not, State Reason:
Enclosed is a copy of the audit report package (pdf copy preferred.)
9. Which method of accounting do you use?
Accrual
Modified Accrual
Cash
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
10. Electronic modules and journals used in Accounting System:
General ledger
Cash receipt journal
Cash disbursement journal
Payroll register
Timesheet
A/R ledger
A/P ledger
Cost Allocation
Fixed Assets
Human Resources
11. Name of accounting system(software) used:
12. Does your financial management system provide records that can identify the source and ap-
plication of funds for award supported activities, and track expenditures by project number
(Federal award) and against budgeted line items?
Yes No
If no, please explain.
13. List the names of the employees performing the following functions:
Activity Employee (First and Last Name)
Cashier (receiving pay-
ments)
Opening Mail
Restrictively endorsing
checks
Preparing deposits
Verifying daily receipts
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
Entering daily receipts
Reconciling bank accounts
Payroll
14. Does the Board of Directors receive regular updates on financial status of the organization
and specific Federal awards? Yes No
If no, explain:
15. Are the Board minutes available upon request? Yes No
16. Are there written procedures for:
If yes, provide a copy of
Inventory Controls - 45 CFR Part 75.320 Yes No
Accounting Policies - 45 CFR 75.403.400 Yes No
Purchasing guidelines - 45 CFR Part 75.327h, 45 CFR Part 75.328 Yes No
17. Provide a copy of the personnel policy manual. Do you have a formal, written personnel pol-
icy that addresses:
Pay Rates and Benefits - 45 CFR Part 75.430,75.431 Yes No
Time and Attendance Yes No
Leave Yes No
Conflict of Interest - 45 CFR Part 75.327(c) (1) Yes No
18. With respect to the conflict of interest provision of the contract, are there any situations
which have not previously been disclosed? Yes No
If yes, please explain:
19. Was the organization a party to a business transaction with a family member of a current or
former officer, director, trustee, or key employee? Yes No
20. Is there a separate bank account for payroll? Yes No
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
21. Do you outsource your payroll? Yes No
Explain your payroll process:
22. Are the payroll checks signed by someone independent of the payroll clerk?
Yes No
Who?
If not, why?
23. Provide a narrative description of your cost allocation plan.
a) How do you track and control time spent on different activities to ensure that time and
efforts are billable to the funding source receiving the benefit(s)?
Describe:
b) How do you allocate labor/non-labor cost not directly associated to a program?
Describe:
c) How do you allocate your facilities costs?
Describe:
d) How do you allocate your general office expenses?
Describe:
24. Do you have a negotiated federally approved indirect cost rate?
Yes No
If yes, please provide the following information:
• Name of the cognizant agency:
• Provisional rate:
• Definition of the base:
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
Provide a copy of your federally approved provisional indirect cost rate agreement.
25. What is the reconciliation process for the bank accounts?
Describe:
26. What is the process for handling money/donations on-site?
Describe:
27. Who signs the checks and is there a double endorsement?
Describe:
28. Please describe the method used to support labor and benefit charges.
Describe:
29. Do you receive other sources of income to operate your program? Yes No
If yes, please list:
30. How is your financial audit funded (if required) pursuant to contract obligations?
Describe:
31. In your single audit, are Federal award funds paid to your agency by EHSD listed in the
Schedule of Federal Awards by contract number and Assistance Listing number?
Yes No Not applicable
If no, please explain:
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
32. Do you Cash Match/In-Kind Match for the funding? Yes No
If so, what is the source of the match? (Example: volunteer hours calculated by market
value)
Describe:
33. Do you use any other Federal funding source as match for this subaward? Yes No
Describe:
34. Do you use Contra Costa subaward funds as match for any other contract? Yes
No
If yes, please explain:
35. Explain your asset control model. How do you track inventory purchased by the subaward
funds?
Describe:
36. Describe your purchasing policy and practice. (How is a vendor selected? Bidding, small
business enterprise, etc.)
Describe:
37. Explain your travel policy as related to Federal award funds.
Describe:
38.At any time, has there been a security breach including wrongful access, inspection, use or
disclosure of confidential information at your agency? Yes No
If yes, please explain the nature of the breach and your process to mitigate:
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
39. Do you subcontract any of the EHSD awarded funds? Yes No
If yes, what type of monitoring procedure do you conduct?
FFATA Reporting
As required by the Federal Accountability and Transparency Act of 2006 (FFATA), Federal
agencies, and non-federal agencies receiving federal funds, are required to report to the
federal government specific information associated with subrecipients of subawards
(i.e., grants) over $30,000, as well as executive compensation amounts for the five most
highly compensated executives of your organization should you meet certain threshold
reporting requirements as listed below.
Executive Compensation Questions (see definitions on next page) Place an X under
Yes or No
Our organization received 80 percent or more of its annual gross revenues from Federal procurement con-
tracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2
CFR 170.320 (and subawards).
Yes
No
Your organization received $25,000,000 or more in annual gross revenues from federal procurement con-
tracts (and subcontracts), and Federal financial assistance subject to the Transparency Act (and subawards).
Yes
No
The public does NOT have access to information about the compensation of the executives through periodic
reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d))
or section 6104 of the Internal Revenue Code of 1986. (To determine if the public has access to the compen-
sation information, see the U.S. Security and Exchange Commission total compensation filings at
http://www.sec.gov./answers/execomp.htm.).
Yes
No
If you answered yes to ALL three executive compensation questions above, complete the table below:
Names of 5 Mostly Highly Compensated Executives Compensation for Preceding Completed Fiscal Year
1)
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 4
Names of 5 Mostly Highly Compensated Executives Compensation for Preceding Completed Fiscal Year
2)
3)
4)
5)
Please write legibly, number attachments, and answer all questions on this form (soft copy is
available). Please email or fax requested single audit and financial statements, and other docu-
ments provided for our review. We will contact you with any additional questions.
I certify that the above information accurately represents the organization of which I am a repre-
sentative.
Date:
Name of Person Completing Questionnaire
Title of Person Completing Questionnaire
Phone number and email address of Person Completing Questionnaire
I attached the following documents for your review:
1.
2.
3.
4.
5.
Please email to: ______________@ehsd.cccounty.us
Fax number:
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 5
APPENDIX 5: RISK ASSESSMENT MATRIX
DEPARTMENTAL FISCAL
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 5
Risk Assessment Matrix - Contract Number(s):______________ Subrecipient Name:
______________
How to use: The Risk Assessment Matrix is used by fiscal analysts in conjunction with the Subrecipient Questionnaire to assess the level of risk
posed by the subrecipient. After assessing the risk level in each of the categories, the fiscal analyst should determine the aggregate level of risk
for the subrecipient using his/her best judgment. The fiscal analyst should consider increasing the level of risk when the information is unknown
in multiple categories.
Based on my assessment, the Subrecipient’s risk is assessed at (circle): Low Moderate High
Completed by: ____________________________ (Print name and date)
Category Low Risk Moderate Risk High Risk
Un-
known
(ex-
plain)
Maturity of organization Mature (e.g. more than 10
years)
Mature, but new to gov-
ernment contracts Start-up, first year in business
Staffing and management Experienced staff and man-
agement; low turnover Medium turnover
High turnover, new management
team
Aware of existing or pend-
ing litigation
No legal action against or-
ganization
Possible legal action
against organization In litigation
Organization type Non-profit, subject to Single
Audit requirements Non-profit – external audit
For- profit, unaudited financial
statements
Subrecipient's prior experi-
ence with the same or simi-
lar subawards Over three years Two to three years One year or less
Complexity of subaward
Provides single service to
specific population
Provides multiple services
to diverse populations
Makes eligibility determinations;
performance impacts objectives of
the federal program; recruits partic-
ipants
Approximate amount of to-
tal Federal awards funded
by EHSD Less than $100,000 $100,001-$684,999 Over $685,000
Federal awards from agen-
cies other than EHSD Yes Yes, but very few None
Large share of revenues
from non-federal awards
Organization has multiple
sources of revenue
Organization has two
sources of revenue
Organization is dependent on a
single source of revenue
Audit report
Has annual audit as re-
quired by Uniform Guid-
ance Subpart F with no
open or close finding in cur-
rent and prior years
Has annual third-party fi-
nancial audit only
or
finding(s) were identified
single audit, but have
been corrected
Has not had annual or financial au-
dit
or
finding(s) are present in current or
prior year single audit
Subrecipient identified as
high Risk in Single Audit re-
port No
Yes, in prior year single
audit only
Yes, in prior and current year sin-
gle audit
Prior Management Decision
Letters No response required Items of concern Corrective action required
Accounting/Procurement
Systems from Response to
Subrecipient Questionnaire
and Recent Audit
No internal control defi-
ciency identified in recent
audit(s) and/or Response to
Subrecipient Questionnaire
Entity is mature and has a
history of receiving federal
awards with no evidence of
recent findings
No internal control defi-
ciency identified in recent
audit(s) and/or Response
to Subrecipient Question-
naire
Little information is availa-
ble on entity’s history with
Federal awards
Internal control deficiency identified
in recent audit(s) and/or Response
to Subrecipient Questionnaire
or entity has never been audited
(review or compilation only)
Other indicators that no systems
are in place or systems are new
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 5
Financial management sys-
tem
Allows tracking award sup-
ported activities against
budgeted line items
Manual tracking of award
supported activities
against budgeted line
items
Does not allow tracking expendi-
tures against line items
Internal control from Re-
sponse to Subrecipient
Questionnaire and Recent
Audit
Strong; proper separation
of duties; low chance for
undetected fraud
Controls vary from weak to
strong depending upon
function
Weak; small organization where
one employee performs many du-
ties; high chance for employee
fraud
Records security Subrecipi-
ent Questionnaire and Re-
cent Audit
Confidential records se-
cured and property dis-
posed; no reported security
violations
Confidential records se-
cured; violation reported in
prior years Security breach within a year
Funds claiming compliance Billing frequency as agreed
in the contract Delays in billing
No billing until the end of the pro-
ject. History of late billing
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 6
APPENDIX 6: SUBRECIPIENT MONITORING PLAN
DEPARTMENTAL FISCAL
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 6
Subrecipient Monitoring Plan
The Subrecipient Monitoring Plan should follow the completion of the Risk Assessment Matrix and review of the Subrecipient Questionnaire. The
Fiscal Analyst should select the Subrecipient Monitoring Plan according to the assessed level of risk and prior findings evidenced in prior year
single audit(s) or monitoring results.
For All Subrecipients:
Analyst Name and Bureau:
Contract Number and Contractor Name: AL and Program Name:
Subrecipient Determination Form Completed on:
Risk Assessment Completed on: Level of Risk (Circle): Low Moderate High
Low Risk Subrecipient – Monitoring Plan #1 Frequency Tool √
1. Send prior year single audit certification survey to each subrecipient to determine
whether subrecipient is subject to Single Audit requirements.
Annually Single Audit
Certification
Survey
□
2. Review Single Audit for findings and accuracy of SEFA. Annually if sub-
ject to single au-
dit
Single Audit
Checklist
□
3. Review audited financial statements to assess financial stability. Review auditor’s opinion
and internal control report.
Annually if sub-
ject to single au-
dit or audited F/S
F/S Checklist □
4. Review responses to Subrecipient Questionnaire to detect potential issues. Annually Subrecipient
Question-
naire
□
5. Review monthly financial reports (demands) for each subrecipient. Monthly Demands Re-
view Guide
□
If not subject to Single Audit or if relevant findings are detected in subrecipient’s prior year Single Audit/monitoring:
6. Conduct desk review. Annually Desk Review
Checklist
□
Moderate Risk Subrecipient – Monitoring Plan #2 Frequency Tool √
1. Send prior year single audit certification survey to each subrecipient to determine
whether subrecipient is subject to Single Audit requirements.
Annually Single Audit
Certification
Survey
□
2. Review Single Audit for findings and accuracy of SEFA. Annually if sub-
ject to single au-
dit
Single Audit
Checklist
□
3. Review audited financial statements to assess financial stability. Review auditor’s opinion
and internal control report.
Annually if sub-
ject to single au-
dit or audited F/S
F/S Checklist □
4. Review responses to Subrecipient Questionnaire to detect potential issues. Annually Subrecipient
Questionnaire
□
5. Review monthly financial reports (demands) for each subrecipient. Monthly Demands Re-
view Guide
□
6. Conduct desk review. Annually Desk Review
Checklist
□
If not subject to Single Audit or if relevant findings are detected in subrecipient’s prior year Single Audit/monitoring:
7. Conduct monitoring on-site. Annually On-site
Checklist
□
High Risk Subrecipient – Monitoring Plan #3 Frequency Tool √
1. Send prior year single audit certification survey to each subrecipient to determine
whether subrecipient is subject to Single Audit requirements.
Annually Single Audit
Certification
Survey
□
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 6
High Risk Subrecipient – Monitoring Plan #3 Frequency Tool √
2. Review Single Audit for findings and accuracy of SEFA. Annually if sub-
ject to single au-
dit
Single Audit
Checklist
□
3. Review audited financial statements to assess financial stability. Review auditor’s opinion
and internal control report.
Annually if sub-
ject to single au-
dit or audited F/S
F/S Checklist □
4. Review responses to Subrecipient Questionnaire to detect potential issues. Annually Subrecipient
Questionnaire
□
5. Review monthly financial reports (demands) for each subrecipient. Monthly Demands Re-
view Guide
□
6. Conduct monitoring on-site. Annually On-site
Checklist
□
CSB Delegate Subrecipient – Monitoring Plan #4 Frequency Tool √
1. Send prior year single audit certification survey to each subrecipient to determine
whether subrecipient is subject to Single Audit requirements.
Annually Single Audit
Certification
Survey
□
2. Review Single Audit for findings and accuracy of SEFA. Annually if sub-
ject to single au-
dit
Single Audit
Checklist
□
3. Review audited financial statements to assess financial stability. Review auditor’s opinion
and internal control report.
Annually if sub-
ject to single au-
dit or audited F/S
F/S Checklist □
4. Review responses to Subrecipient Questionnaire to detect potential issues. Quarterly Subrecipient
Questionnaire
□
5. Review monthly financial reports (demands) for each subrecipient. Monthly Demands Re-
view Guide
□
6. Conduct monitoring on-site. Quarterly On-site
Checklist
□
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 7
APPENDIX 7: GUIDELINES TO REVIEW MONTHLY DEMANDS
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 7
Guidelines to Review Subrecipient Monthly Financial Reports (demands)
This document is intended to assist Program Analysts and Account Clerks with reviewing and processing monthly
financial reports (demands). The purpose of the review is to ensure that financial reports (demands) include proper
documentation, support, and approvals. Requests for reimbursement should be submitted timely (monthly, quar-
terly) as stated in the contract.
In cases where unresolved non-compliance issues by subrecipients are detected during the fiscal monitoring or other
means, the designated Fiscal staff will review the monthly demands as needed until the non-compliance issues are
resolved by subrecipient.
Program Analyst – Bureau – Demand Review
1. Date stamps the demand when received.
2. Verifies that a valid contract is on file.
3. Review the budget for allowability, allocability and reasonableness before a contract is executed and when
the budget in subsequently amended.
4. Invoice should provide additional understanding of a project’s financial performance in relation to
task/milestones/deliverable status
5. Invoices should go hand-in-hand with progress toward the milestones/tasks in the project SOPO.
6. Reject invoices missing or have incorrect required documentation including invoice attestation form.
7. Reject invoices with no supporting documentation
8. Checks the demand Form D15 for completeness.
9. Do not alter/change any amount on the D15 or invoice submitted by the subrecipient/contractor. Request a
corrected D15 as well as invoice from subrecipient/contractor.
10. Verifies that the work billed for was performed, and that proper documentation is attached.
11. Verifies that each cost item on the demand corresponds to the line item in the current budget 2.
12. Verifies that each line item on the demand does not exceed the amount listed in the budget.
13. Verifies that each cost, when rounding, does not exceed the budgeted amount.
14. Signs and retains a copy of Form D15 with back up, prior to sending it to Fiscal Unit.
Account Clerk – Fiscal Unit
1. Date stamps the demand when received and log.
2. Reviews the demand for completeness.
a. Vendor information, completed name, address and signature
b. Authorizing signature (program analyst or higher)
i. If no authorizing signature:
1. Returns original demand back to program analyst for needed information
2 The budget is reviewed for allowability, allocability and reasonableness before the contract is executed and when the budget is
subsequently amended.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 7
2. When the demand is received (with necessary information), another date stamp
is required.
3. Verifies billing information on the demand to confirm:
a. Billed month falls within contract period
i. If not, checks to see if fiscal has received a contract amendment or renewal
ii. If no amendment or renewal, Account Clerk sends an email to Account Clerk Supervisor
who sends an email to the Contract Unit’s Clerk requesting the status on the contract re-
newal
b. Insurance covers FULL billing period (i.e. If demand is for the month of January, the Insurance
Clearance must expire on or after January 31st.)
i. Account Clerk sends an email to the Account Clerk Supervisor, if Insurance Clearance
does not cover the full period. Account Clerk Supervisor sends an email to Contract
Unit’s Clerk requesting an updated Insurance Clearance prints a copy of email and at-
taches it to the demand, as the demand cannot be processed. Places demand in Demand
Issues Folder, waiting for insurance, etc.
4. Enters current month’s billing information onto the Excel Spreadsheet.
a. For each line item in the budget verifies that expenses:
i. DO NOT exceed the total contract limit.
ii. If total exceeds contract limit, the Account Clerk (AC) will notify the Account Clerk Su-
pervisor (ACS), because the AC or ACS cannot reduce or alter a submitted demand/in-
voice amount. The demand/invoice is returned to the Program/Fiscal Analyst who con-
tacts the vendor.
iii. Line items are not over limit by more than 10%, if applicable, per language in the con-
tract. If line item is over by more than 10%, a line item adjustment is required. Sends an
email to the program/fiscal analyst requesting a line item adjustment.
iv. If a line item adjustment is needed, demands are held pending receipt/confirmation of the
adjustment.
7. Encodes information onto demand:
a. Enters Vendor# in Vendor # box on the mid left side of the demand and top box.
b. Dates the demand using demand or invoice date
c. Writes description in the following format: mm/yy, contractor
i. Invoice#, if applicable, if not, data of services, mm/yy – invoices go last so A/P has it in
uniform order
ii. Contractor’s name of abbreviation
iii. Date services mm/yy, only of there is an invoice#
d. Includes Org# and Option codes from spreadsheet
i. If multiple Org#s and option codes, list each org on a different line. If more than three (3)
lines, use TC52 Form.,
e. Records account number as 2310
f. P/C (only used if contract is encumbered). P = Partial Payment against the contract, C=Close En-
cumbrance (last payment only, contract is complete) – ONLY CSB
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 7
g. Writes payment amount.
8. Date stamp the demand when it’s going to A/P and when processed, stamps “contract”, records the date the
demand was processed on the bottom of the demand and when it’s going to A/P.
9. Scan demands with backup and save to subrecipient folder, spreadsheet is also saved to the subrecipient
folder.
10. Redacts confidential information from the original demand.
11. Signs the demand.
12. Sends original demand to Account Payable-Contracts at the Auditor-Controller’s office.
13. Checks Auditor-Controller’s Intranet for last payment information (http://audi-
tor.co.contra-costa.ca.us/)
a. Select Accounts Payable
b. Select Vendor History
c. Enter P.O.# (Encumbrance # from demand)
d. Click box next to “include ‘F’ pays”
e. Click search
14. Records prior month’s payment information onto the EXCEL Spreadsheet maintained
at \\fshare3\fiscal\Payment\Contracts\Excel\Spreadsheets
a. Warrant Number
b. Issuance Date
c. If new vendor, Fiscal Clerk updates vendor number on the spreadsheet
and on the Contract List.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 63
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 63
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
APPENDIX 8: DESK REVIEW GUIDE
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 64
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 64
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
Desk Review Guide
This desk review tool can be adapted as needed by the user. Please line out the steps rather than
deleting them if they are not needed for the review you are conducting and provide a justification
in the comment section. Add steps as needed based on your preliminary review prior to your
desk review.
Please complete the following section:
Subrecipient Name:
Subaward Number:
Subaward Amount:
Funding Sources and AL:
Analyst conducting the re-
view:
Subrecipient’s Fiscal Of-
ficer:
Before using this desk review tool, answer the following questions:
Pre-Desk Review Activities Questions: YES / NO
1. Was the Annual Subrecipient/Contractor Determination checklist com-
pleted?
Yes No
2. Was the determination made that the entity is a subrecipient? Yes No
3. Was the Single Audit Certification sent to the Subrecipient? Yes No
4. Did the subrecipient indicate on Single Audit Certification form that the
subrecipient entity is subject to 2 CFR 200 Part F - Single Audit Re-
quirements?
Yes No
5. If the answer is yes to 5, did EHSD receive the latest subrecipient single
audit and was the Single Audit Review checklist completed?
Yes No
6. Was the Annual Subrecipient Questionnaire sent to the subrecipient? Yes No
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 65
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 65
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
7. Were the subrecipient’s responses to the Annual Subrecipient Question-
naire and Single Audit Review Checklist used to complete the Risk
Analysis Matrix?
Yes No
8. Was the subrecipient risk level assessed HIGH upon reviewing the risk
categories listed in the Risk Assessment Matrix?
Yes No
9. If the answer to 8 is no, was the subrecipient risk level assessed MOD-
ERATE and did the subrecipient had finding(s) in the previous EHSD
monitoring report or finding(s) in the prior year Single Audit?
Yes No
10. If the answers to 8 and 9 are no, STOP here and GO back to the subre-
cipient monitoring plan to verify if the subrecipient is subject to a desk
review.
Yes No
Desk Review Planning Phase
A Steps Completed (√). Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
1. Contact program analyst before notifying subrecipient
about the desk review and obtain the following infor-
mation:
• Date of last program review or site visit
• Copy of report if subrecipient had program
findings or service concerns
• Copy of subrecipient corrective action plan and
timeline
2. Gain an understanding of the rules and regulations ap-
plicable to the subrecipient Federal subawards:
• Obtain AL number and program name
• Review fiscal section of grant agreement, if ap-
plicable
• Review contract special conditions
• Review Federal Cost Principles section in 2
CFR 200, 45 CFR 75 or other applicable CFRs
• Review applicable State guidance on fiscal
compliance
3. Gain an understanding of the subrecipient fiscal condi-
tions by reviewing the following documents:
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 66
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 66
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
A Steps Completed (√). Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
• Latest subrecipient Single Audit and completed
Single Audit Review checklist
• Subrecipient’s responses to Annual Subrecipi-
ent Questionnaire
• Completed Risk Assessment Matrix
• Annual contract budget
• Monthly Financial Reports (demands)
• Contract Budget v. Actual by line item Report
• Obtain and review payment history from the
Auditor-Controller’s Intranet site
4. Review subrecipient submitted year-to-date expendi-
tures and determine type of costs to be reviewed dur-
ing the desk review. Consider prior EHSD monitoring
results, single audit findings and areas of risk identified
during preliminary review in determining the selection
of cost items.
Sample at least one monthly demand based on follow-
ing considerations:
• Dollar amount of demand relative to total con-
tract (subaward)
• Determine the major cost elements by calculat-
ing the percentage to total by cost element in
the subrecipient’s annual contract budget
• Major cost elements as measured by percentage
to total annual contract budget (i.e. salaries, fa-
cilities and supportive services) represented on
sampled demand
• If prior monitoring or audit findings, attempt to
select a demand that will allow the monitor to
assess whether the corrective action plan was
adequately implemented
5. Inform subrecipient of desk review and request list of
items.
• Prepare and mail notification letter to subrecip-
ient with a copy to program analyst
• Inform the subrecipient that the fiscal monitor
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 67
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 67
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
A Steps Completed (√). Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
will review the responses/ statements to the
Annual Subrecipient Questionnaire sent earlier
during the fiscal year. Cost items claimed on
the sampled monthly demand will be verified
during the desk review
• Attach to notification a request for items to be
reviewed during desk review.
General Items
o Cost Allocation Plan
o Indirect Cost Agreement, if applicable
o Chart of Accounts
o Accounting Policies/Procedures
o If responses to Annual Subrecipient
Questionnaire were incomplete (i.e.
org chart not provided) or unclear, re-
quest that the information be provided
prior to conducting desk review
For Monthly Sample Demand
o Detailed Expenditures and Revenue
Transaction Ledger
o Check Registers
o Payroll Registers
o Time Studies/Time Sheets
o Invoices and purchase orders/contract
o Cancelled Checks or detailed bank
statement showing check numbers
o Travel Vouchers
o Property Inventory Control Listing, if
applicable
Above listed items must be submitted electronically to
fiscal analyst who is conducting the desk review prior
to the desk review date.
6. Review and evaluate documents received from subre-
cipient in response to the request. Make a list of miss-
ing documents.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 68
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 68
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
A Steps Completed (√). Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
7. Tailor the desk review steps to the areas of risk
identified during the review of responses to Subre-
cipient Questionnaire and submitted documents.
Other Steps as Needed
During Desk Review
B General Steps Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Review written accounting procedures and pertinent poli-
cies (travel, purchasing) for the items selected under re-
view.
Other Steps as Needed
C
Selected Cost Item - Personnel cost Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Select one or two employees listed on invoice and com-
pare to org chart to ensure they are working on the pro-
grams funded by the contract being monitored.
2. Obtain timesheet for each employee and trace cost center
code to chart of accounts. If hours worked by the selected
employee are pooled, compare the cost pool allocation
methodology from the subrecipient’s cost allocation to
how the hours were allocated to the benefiting programs.
Verify that the base of allocation is reasonable and ade-
quately supported by actual numbers.
3. Obtain payroll register and compare employee total salary
to documented salary in the document authorizing that
amount.
4. Compare check number on payroll register to bank state-
ment to verify that the check cleared. If the subrecipient
uses EFT, verify that the check number is on the positive
pay file submitted to the bank. Then verify that the total
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 69
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 69
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
C
Selected Cost Item - Personnel cost Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
amount from the positive pay file cleared the bank per the
bank statement.
5.
Trace cost from payroll register to general ledger. Use time-
sheet to calculate cost center hours to-total hours ratio.
Apply ratio to employee salary from payroll register and
compare calculated amount to amount in the general
ledger for the cost center code designated for this con-
tract. This step may need to be modified depending on the
Subrecipient’s payroll process in place. The calculated
amount should match the general ledger and sampled
monthly invoice.
Other Steps as Needed per Risk Level
D Selected Cost Item - Non-personnel cost (space) Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvement are Needed
1. Obtain total cost and square footage from lease agreement
and calculate monthly rent.
2. Request detailed ledger disclosing rent transaction and as-
sociated documentation supporting rent cost billed on
sampled monthly invoice.
3. Review a/p supporting documentation and verify that the
correct amount of payment was made to landlord listed on
lease agreement. Compare check number to bank state-
ment to verify that the check cleared.
4. Determine space allocation methodology from the subre-
cipient’s cost allocation plan.
5. Verify that the share of rent billed to the contract for the
sampled monthly invoice was appropriately allocated in
accordance with the cost allocation plan. If cost allocation
plan is not provided (may result in an administrative find-
ing), verify that the share of rent cost billed to the contract
is reasonable based on a sound methodology. If methodol-
ogy is not sound or adequately supported by accounting
records/lease, this may result in a cost disallowance.
Other Steps as Needed per Risk Level
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 70
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 70
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
E Selected Cost Item - Non-personnel cost (vendor/sub-recipient) Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvement are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting cost (i.e. office supplies,
contracted services) billed on sampled monthly invoice.
Documentation should include the following:
• Authorization to purchase (requisition, PO, etc.)
with appropriate signature in accordance with or-
ganization’s signature authority.
• For contracted services, obtain a copy of the con-
tract to verify payment conditions.
• Price reasonableness.
• Indicator showing that the goods/services were re-
ceived and vendor invoice.
2. Verify that the goods/services purchased benefitted
program funded by contract being monitored and that
the cost is recorded in the appropriate cost center.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
F Selected Cost Item - Non-personnel cost (travel) Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting travel cost billed on sam-
pled monthly invoice. Documentation should include the
following:
• Authorization to travel and travel reimbursement
form with appropriate signature in accordance
with organization’s signature authority.
• Travel receipts for hotel, airfare and other travel
cost. If organization uses per diem, verify that the
per diem does not exceed the federal per diem
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 71
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 71
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 8
F Selected Cost Item - Non-personnel cost (travel) Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
schedule. If per diem is higher, an additional step
may be necessary to determine reasonableness of
the per diem (not supported by receipt).
2. Verify that the cost is recorded in the appropriate cost cen-
ter.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
Post Activities after Desk Review
G Summarize Desk Review Completed (√) Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Make copies of evidence supporting findings, if any.
During the review, cross reference contract and CFR/OMB
references supporting findings, if any.
2. Write draft monitoring report.
3. Provide copy of draft desk review report to Fiscal Officer or
his/her designee for review.
4. Finalize desk review report and mail to subrecipient.
5. If findings are in desk review report, request corrective ac-
tion plan with timetable.
6. Follow up with subrecipient on corrective action plan per
timetable and verify during the next annual monitoring
that is implemented.
7. File electronically desk review documents and inform
Compliance Accountant of desk review outcomes.
Other Steps as Needed per Risk Level
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 72
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 72
EFFECTIVE: 5-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
APPENDIX 9: ONSITE MONITORING GUIDE
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 73
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 73
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
On-site Fiscal Monitoring Tool
This monitoring tool can be adapted as needed by the user. Please line out the steps rather than
deleting them if they are not needed for the review you are conducting and provide a justification
in the comment section. Add steps as needed based on your preliminary review prior to your
monitoring visit.
Please complete the following section:
Subrecipient Name:
Subaward Number:
Subaward Amount:
Funding Sources and AL:
Analyst conducting the re-
view:
Subrecipient’s Fiscal Of-
ficer:
Before using this onsite monitoring tool, answer the following questions:
Pre-Onsite Monitoring Activities Questions: YES / NO
1. Was the Annual Subrecipient/Contractor Determination checklist com-
pleted?
Yes No
2. Was the determination made that the entity is a subrecipient? Yes No
3. Was the Single Audit Certification sent to the Subrecipient? Yes No
4. Did the subrecipient indicate on Single Audit Certification form that the
subrecipient entity is subject to 2 CFR 200 Part F - Single Audit Re-
quirements?
Yes No
5. If the answer is yes to 4, did EHSD receive the latest subrecipient single
audit and was the Single Audit Review checklist completed?
Yes No
6. Was the Annual Subrecipient Questionnaire sent to the subrecipient? Yes No
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 74
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 74
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
7. Were the subrecipient’s responses to the Annual Subrecipient Question-
naire and Single Audit Review Checklist used to complete the Risk
Analysis Matrix?
Yes No
8. Was the subrecipient risk level assessed HIGH upon reviewing the risk
categories listed in the Risk Assessment Matrix?
Yes No
9. If the answer to 8 is no, was the subrecipient risk level assessed MOD-
ERATE and did the subrecipient had finding(s) in the previous EHSD
monitoring report or finding(s) in the prior year Single Audit?
Yes No
10. If the answers to 8 and 9 are no, STOP here and GO back to the subre-
cipient monitoring plan to verify if the subrecipient is subject to a desk
review.
Yes No
Onsite Monitoring Planning Phase
A Steps NOTE: Document what was asked, re-
sponse, list documents reviewed and
state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
1. Contact program analyst before notifying subrecipient
about the onsite monitoring review and obtain the fol-
lowing information:
• Date of last program review or site visit
• Copy of report if subrecipient had program
findings or service concerns
• Copy of subrecipient corrective action plan
and timeline
2. Gain an understanding of the rules and regulations ap-
plicable to the subrecipient Federal subawards:
• Obtain AL number and program name
• Review fiscal section of grant agreement, if
applicable
• Review contract special conditions
• Review Federal Cost Principles section in 2
CFR 200, 45 CFR 75 or other applicable CFRs
• Review applicable State guidance on fiscal
compliance
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 75
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 75
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
A Steps NOTE: Document what was asked, re-
sponse, list documents reviewed and
state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
3. Gain an understanding of the subrecipient fiscal condi-
tions by reviewing the following documents:
• Latest subrecipient Single Audit and com-
pleted Single Audit Review checklist
• Subrecipient’s responses to Annual Subrecipi-
ent Questionnaire
• Completed Risk Assessment Matrix
• Annual contract budget
• Monthly Financial Reports (demands)
• Contract Budget v. Actual by line item Report
• Obtain and review payment history from the
Auditor-Controller’s Intranet site
4. Review subrecipient submitted year-to-date expendi-
tures and determine type of costs to be reviewed dur-
ing on-site visit. Consider prior EHSD monitoring re-
sults, single audit findings and areas of risk identified
during preliminary review in determining the selection
of cost items.
Sample at least one monthly demand based on follow-
ing considerations:
• Dollar amount of demand relative to total con-
tract (subaward)
• Determine the major cost elements by calcu-
lating the percentage to total by cost element
in the subrecipient’s annual contract budget
• Major cost elements as measured by percent-
age to total annual contract budget (i.e. sala-
ries, facilities and supportive services) repre-
sented on sampled demand
• If prior monitoring or audit findings, attempt
to select a demand that will allow the monitor
to assess whether the corrective action plan
was adequately implemented
5. Inform subrecipient of onsite monitoring visit and re-
quest list of items.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 76
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 76
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
A Steps NOTE: Document what was asked, re-
sponse, list documents reviewed and
state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
• Prepare and mail notification letter to subre-
cipient with a copy to program analyst
• Inform the subrecipient that the fiscal moni-
tor will review the responses/ statements to
the Annual Subrecipient Questionnaire sent
earlier during the fiscal year. Cost items
claimed on the sampled monthly demand will
be verified during the onsite monitoring visit
• Attach to notification a request for items to be
reviewed before and during onsite monitoring
General Items
o Cost Allocation Plan
o Indirect Cost Agreement, if applicable
o Chart of Accounts
o Personnel Manual
o Accounting Policies
o Purchasing Guidelines
o If responses to Annual Subrecipient
Questionnaire were incomplete (i.e.
org chart not provided) or unclear, re-
quest that the information be provided
prior or during the onsite monitoring
visit
For Monthly Sample Demand
o Detailed Expenditures and Revenue
Transaction Ledger
o Check Registers
o Payroll Registers
o Time Studies/Time Sheets
o Invoices and purchase orders/contract
o Cancelled Checks or detailed bank
statement showing check numbers
o Travel Vouchers
o Property Inventory Control Listing
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 77
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 77
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
A Steps NOTE: Document what was asked, re-
sponse, list documents reviewed and
state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
(PICL), if applicable. Verify if PICL in-
formation includes requirements un-
der 45 CFR Part 75.320(d)(1).
6. Review and evaluate documents received from subre-
cipient in response to the request. Make a list of miss-
ing documents.
7. Prepare a list of questions for the entrance confer-
ence and on-site visit that are tailored to the areas of
risk identified during the review of responses to Sub-
recipient Questionnaire and submitted documents.
Conflict of Interest
8. Review Conflict of Interest of the Subrecipient Con-
tract General Conditions.
9. Verify if there is a modification of the Conflict of Inter-
est provisions in of the Subrecipient’s Contract Special
Conditions. Review the additional language if a modi-
fication is identified in the Special Conditions.
10. Research the applicable Code of Federal Regulations
on Conflict of Interest for additional guidance - 45 CFR
Part 75.327(c).
11. Review subrecipient’s written conflict of interest pol-
icy and verify if the policy is in alignment with the
Subrecipient’s Contract General Conditions and Spe-
cial Conditions, if applicable.
Other Steps as Needed
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 78
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 78
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
During Onsite Monitoring Visit
B General Steps NOTE: Document what was
asked, response, list documents
reviewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Conduct entrance conference. Collect sign-in sheet with
list of attendees.
2. Meet with fiscal officer to go over contract monitoring
questionnaire and submitted documents. Clarify items as
needed and obtain the missing documents, if any, from the
requested document list.
3. Ask fiscal officer to describe the process in place for the
following items:
4. • Preparation of monthly/quarterly invoice (de-
mand)
5. • Org chart in relation to accounting functions, inter-
nal control and signature authority.
6. • Personnel costs billed to contract
o Time sheet completion and sign off
o Determination of cost centers for time
charges and cost allocation plan
o Payroll process from timesheet comple-
tion to printing/ETF to posting of payroll
to ledger
o Employee benefits and payroll taxes
7. • Non-personnel costs billed to contract
o Accounts payable process from purchase
authorization (requisition/purchase order)
to processing vendor payment and issuing
checks/ETF
o Space cost billed to contract, including
lease agreement and cost allocation plan
o Vendor and sub-recipient agreement and
issuance of payment
o Process for selecting vendors and sub-re-
cipients
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
B General Steps NOTE: Document what was
asked, response, list documents
reviewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
o Process for authorizing and reimbursing
employee travel
8. • In-Kind/Cash Match reported to EHSD (only if the
contract requires a match)
o Valuation system for In-Kind services and
donated goods
o Maintenance of records system for In-Kind
services and donated goods
o Tracking system for reporting cash match
9. Obtain and review written accounting procedures for the
above items and pertinent policies (travel, purchasing).
10. Request supporting documentation for selected items of
cost from the sampled monthly/quarterly invoice (de-
mand). Selected items of cost may vary based on result of
risk assessment. See boxes below for additional details.
Conflict of Interest
11. Perform onsite interviews on a sample basis with various
management staff overseeing functions such as finance,
procurement and governance.
12. Identify potential risk and issues using the below sample
of questions.
• Have any of the key executives or Board Members
been associated with other organizations in the
past with which you have a business relationship
and, if yes, what was the nature of those organiza-
tions and relationships?
• Can you describe how you monitor Conflict of In-
terest in your organization?
• Have managers at all levels expressed their com-
mitment to the policy?
• If you have a subrecipient under this contract,
how do you monitor conflict of interest?
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
B General Steps NOTE: Document what was
asked, response, list documents
reviewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
• Is the policy easily accessible to everyone within
the organization and to external partners/ven-
dors?
• Have managers and staff received adequate train-
ing in how to manage and/or report conflicts of in-
terest?
• Is conflict of interest policy and awareness incor-
porated into your recruitment, selection and pro-
curement processes?
How to Solve Conflict of Interest
13. Address conditions under which outside activities, rela-
tionships, or financial interests are proper or improper;
(accepting gifts, disclosing confidential information, out-
side employment).
14. Outline how financial conflicts of interest may be ad-
dressed.
15. Identify when and how the subrecipient must provide dis-
closure, written notification, possible outside activities, re-
lationships, or financial interests to EHSD.
16. Explain the consequences of non-disclosure may result in
additional conditions and could result in suspension or de-
barment.
17. Document and demonstrate compliance efforts.
Other Steps as Needed
C
Selected Cost Item - Personnel cost NOTE: Document what was asked,
response, list documents reviewed
and state findings or results/con-
clusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Select one or two employees listed on invoice and com-
pare to org chart to ensure they are working on the pro-
grams funded by the contract being monitored.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
C
Selected Cost Item - Personnel cost NOTE: Document what was asked,
response, list documents reviewed
and state findings or results/con-
clusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
2. Obtain timesheet for each employee and trace cost center
code to chart of accounts. If hours worked by the selected
employee are pooled, compare the cost pool allocation
methodology from the subrecipient’s cost allocation to
how the hours were allocated to the benefiting programs.
Verify that the base of allocation is reasonable and ade-
quately supported by actual numbers.
3. Obtain payroll register and compare employee total salary
to documented salary in employee’s personnel file.
4. Compare check number on payroll register to bank state-
ment to verify that the check cleared. If the subrecipient
uses EFT, verify that the check number is on the positive
pay file submitted to the bank. Then verify that the total
amount from the positive pay file cleared the bank per
the bank statement.
5.
Trace cost from payroll register to general ledger. Use
timesheet to calculate cost center hours to-total hours ra-
tio. Apply ratio to employee salary from payroll register
and compare calculated amount to amount in the general
ledger for the cost center code designated for this con-
tract. This step may need to be modified depending on the
subrecipient’s payroll process in place. The calculated
amount should match the general ledger and sampled
monthly invoice.
Other Steps as Needed per Risk Level
D Selected Cost Item - Non-personnel cost (space) NOTE: Document what was asked,
response, list documents reviewed
and state findings or results/con-
clusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Obtain total cost and square footage from lease agree-
ment and calculate monthly rent.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
D Selected Cost Item - Non-personnel cost (space) NOTE: Document what was asked,
response, list documents reviewed
and state findings or results/con-
clusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
2. Request detailed ledger disclosing rent transaction and as-
sociated documentation supporting rent cost billed on
sampled monthly invoice.
3. Review a/p supporting documentation and verify that the
correct amount of payment was made to landlord listed
on lease agreement. Compare check number to bank
statement to verify that the check cleared.
4. Determine space allocation methodology from the subre-
cipient’s cost allocation plan.
5. Verify that the share of rent billed to the contract for the
sampled monthly invoice was appropriately allocated in
accordance with the cost allocation plan. If cost allocation
plan is not provided (may result in an administrative find-
ing), verify that the share of rent cost billed to the con-
tract is reasonable based on a sound methodology. If
methodology is not sound or adequately supported by ac-
counting records/lease, this may result in a cost disallow-
ance.
Other Steps as Needed per Risk Level
E Selected Cost Item - Non-personnel cost (vendor/sub-recipient) NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting cost (i.e. office supplies,
contracted services) billed on sampled monthly invoice.
Documentation should include the following:
• Authorization to purchase (requisition, PO, etc.)
with appropriate signature in accordance with or-
ganization’s signature authority.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
E Selected Cost Item - Non-personnel cost (vendor/sub-recipient) NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
• For contracted services, obtain a copy of the con-
tract to verify payment conditions.
• Price reasonableness.
• Indicator showing that the goods/services were re-
ceived and vendor invoice.
2. Verify that the goods/services purchased benefitted
program funded by contract being monitored and that
the cost is recorded in the appropriate cost center.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
F Selected Cost Item - Non-personnel cost (travel) NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting travel cost billed on sam-
pled monthly invoice. Documentation should include the
following:
• Authorization to travel and travel reimbursement
form with appropriate signature in accordance
with organization’s signature authority.
• Travel receipts for hotel, airfare and other travel
cost. If organization uses per diem, verify that the
per diem does not exceed the federal per diem
schedule. If per diem is higher, an additional step
maybe necessary to determine reasonableness of
the per diem (not supported by receipt).
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
F Selected Cost Item - Non-personnel cost (travel) NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
2. Verify that the cost is recorded in the appropriate cost cen-
ter.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
G Exit Conference and Other Items NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Make copies of evidence supporting findings, if any.
During the review, cross reference contract and CFR/OMB
references supporting findings, if any.
2. Conduct exit conference. Collect sign-in sheet with list of
attendees.
Inform attendees of potential administrative findings and
cost disallowance, if any.
3. Be prepared to write monitoring report.
Other Steps as Needed per Risk Level
Post Activities after Onsite Monitoring
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
H Exit Conference and Other Items NOTE: Document what was asked,
response, list documents re-
viewed and state findings or re-
sults/conclusion if no findings.
Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Write draft monitoring report within 10 days of the visit
unless there are extenuating circumstances.
2. Provide copy of draft monitoring report to Fiscal Officer or
his/her designee for review.
3. Finalize monitoring report and mail to subrecipient.
4. If findings are in monitoring report, request corrective ac-
tion plan with timetable.
5. Follow up with subrecipient on corrective action plan per
timetable and verify during the next annual monitoring
that is implemented.
6. File electronically monitoring documents and inform Com-
pliance Accountant of monitoring outcomes.
Other Steps as Needed
Subrecipients of Federal Funding
FFATA Reporting
As required by the Federal Accountability and Trans-
parency Act of 2006 (FFATA), Federal agencies, and
non-federal agencies receiving federal funds, are re-
quired to report to the federal government specific in-
formation associated with subrecipients of subawards
(i.e., grants) over $30,000, as well as executive com-
pensation amounts for the five most highly compen-
sated executives of your organization should you meet
certain threshold reporting requirements as listed be-
low.
Executive Compensation Questions (see definitions on next page)
Place an X under
Yes or No
Our organization received 80 percent or more of its annual gross revenues from Federal procure-
ment contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act,
as defined at 2 CFR 170.320 (and subawards)
Yes
No
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 9
Executive Compensation Questions (see definitions on next page)
Place an X under
Yes or No
Your organization received $25,000,000 or more in annual gross revenues from federal procurement
contracts (and subcontracts), and Federal financial assistance subject to the Transparency Act (and
subawards).
Yes
No
The public does NOT have access to information about the compensation of the executives through
periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15
U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the
public has access to the compensation information, see the U.S. Security and Exchange Commission
total compensation filings at http://www.sec.gov./answers/execomp.htm.)
Yes
No
If you answered yes to ALL three executive compensation questions above, complete the table below:
Names of 5 Mostly High Compensated Executives Compensation for Preceding Completed Fiscal
Year
1)
2)
3)
4)
5)
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 10
APPENDIX 10: FEDERAL AWARD PAYMENT TEMPLATE
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 10
[Sample
Only one letter per Subrecipient
Use AL Worksheet to complete the table]
Date
Address:
Dear (Name of Fiscal Contact):
This letter provides information to be included in the Schedule of Federal Awards (SEFA) for ______ fiscal year.
Pass through from Contra Costa County:
Title Contract Number AL Number Federal Funds
Spent
Please verify this information and contact _______________if there are discrepancies. She/he can be reached at
tel.__________ or email_____________
Sincerely,
Name
Fiscal Officer
Tel.
Email.
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 11
APPENDIX 11: SINGLE AUDIT CERTIFICATION
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 11
Fiscal Unit
Date: Contract Number(s):
To: Period of Performance:
Attn:
Re: Single Audit Requirement Certification for EHSD Contract(s) Fiscal Year
Subject: Title 2: Code of Federal Regulations Part 200, Subpart F – Single Audit Requirements
Your organization is subject to the Single Audit provisions of 2 CFR 200 Part F if it has expended $750,000 or more in Fed-eral awards during the fiscal year, unless the entity is classified as a for-profit corporation. We have determined the contract number(s) listed above was/were funded with one or more Federal awards and are asking that you provide Contra Costa County with the following information. Please check the appropriate box and provide required documents by
We have completed our Single Audit for the most recent period to . The audit disclosed no
material instances of noncompliance with federal laws or regulations or reportable conditions specifically related to the award(s)
from EHSD. Enclosed is a copy of the audit report package.
We have completed our Single Audit for the most recent period to . The audit report noted
material noncompliance issues and/or reportable conditions. Enclosed is a copy of the audit report package and the correc-
tive action plan.
We have not yet completed our Single Audit for the period to . We expect the audit to be
completed on . Within thirty (30) days of completion, we will send you either written notification or a
copy of the audit report package.
We are not subject to the audit requirements of Subpart F because
We expended less than $750,000 in total Federal awards during the fiscal year for EHSD contracts and non-EHSD
funding entities
We are a For Profit Organization
Other (Explain)
Our Fiscal year end is: (Please provide this information so that we can update your record.)
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 11
I certify that the foregoing statements accurately represent the organization of which I am a representative. Further, I certify that all
relevant material findings contained in the audit report, if completed, have been disclosed.
Signature: Title:
Name (Print):
Email:
Thank you for your assistance in complying with this
federal mandate. If you have questions, please feel
free to contact me. My contact information is pro-
vided below. Please send the completed form back to
me via email (preferred) or USPS.
Office Phone: Email: Mailing address: EHSD, Fiscal Unit
40 Douglas Drive
Martinez, CA 94553
Fax: (925) 313-1757
Phone _______________________
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
APPENDIX 12: AUDIT REVIEW CHECKLIST
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SECTION: 25-130
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
Contra Costa County
Employment & Human Services Department
AUDIT REVIEW CHECKLIST
Auditee Name: Fiscal Year End:
Contract Number:
Reviewer:
Date Reviewed:
Instructions:
For single audit (includes audit of financial statements), complete all parts of this document.
For financial statements audit only (subrecipient not subject to $750,000 threshold), complete
Part I, the financial statements section of Part II and Part III of this document.
PART I: General
1. Audit is a:
Financial Statements Audit (subrecipient not subject to $750,000 threshold)
Single Audit (includes audit of financial statements)
Program Specific Audit
2. Auditee’s fiscal period end date:
3. Audit Firm Name:
4. Total Federal Subaward/Award Expended for Fiscal Year: $
5. Number of programs in which Federal funds were expended:
*Note that a Single Audit is required if Federal funds expended equal or exceed $750,000 for fiscal years begin-
ning on or after January 1, 2015).
6. Audit was conducted according to: GAAS GAGAS
7. If no audit was required by 2 CFR §200.501(a), how was the audit paid for?
or N/A
PART II: Audit Component Checklist
The following is a key for the Component Checklist
* = Required (cannot be blank or 'N/A').
** = Required if prior audit findings exist.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
*** = Required if findings exist.
Note: These codes do not apply to a program specific audit.
Financial Statements Section:
Page Number Component
____________ * Financial Statements
____________ * Independent Opinion on Financial Statements
____________ * Report on Internal Control over Financial Reporting
____________ * Report on Compliance
____________ * Management Discussion and Analysis
____________ * Balance Sheet Statement
____________ * Income Statement
____________ * Statement of Cash Flow
____________ * Notes to the Financial Statements
Compliance Over Federal Programs Section (ONLY IF ENTITY SUBJECT TO SINGLE AU-
DIT):
Page Number Component
____________ * Schedule of expenditures of Federal Awards
____________ * Independent Opinion or Disclaimer of Opinion on Schedule of Federal
Awards
____________ * Report on Internal Control (major programs)
____________ * Report on Compliance (major programs)
____________ * Schedule of Findings and Questioned Costs
____________ ** Summary Schedule of Prior Audit Findings
____________ *** Corrective Action Plan (if findings)
____________ Management Letter (if applicable)
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
PART III: FINANCIAL STATEMENTS
1. Type of audit report issued on financial statements:
Mark either:
Unmodified Opinion
Qualified opinion
Adverse opinion
Disclaimer of opinion
2. Is a "going concern" emphasis-of-matter paragraph included in the audit report? Yes
No
3. Is a significant deficiency disclosed? Yes No
4. Is a material weakness disclosed? Yes No
5. Is a material noncompliance disclosed? Yes No
6. Opinion Letter is signed by the CPA: Yes No
7. Calculate liquidity ratio (current assets/current liabilities) _________. Is the entity able to pay off
its short-term liabilities with its current assets? Yes No
8. Calculate the debt ratio (total liabilities/total assets) _________. Is the entity highly dependent
on leverage (debt) to finance its operations? Yes No
9. Does the entity have significant operating lease obligation(s) disclosed in the note to the financial
statements? Yes No if yes, calculate operating lease/total assets ratio:
_________.
10. Does the Contingency note to the financial statements reveal a contingent liability such as an in-
come/payroll tax dispute with a government agency that could potentially lead the entity to owe
a substantial amount tax penalties and interest? Yes No
If yes, please explain:
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
11. Is there a Subsequent Event reported in the notes to the financial statements? Yes
No
If yes, please explain:
12. Does the Significant Accounting Policies note to the financial statements reveal any concerns re-
garding the entity’s ability to meet the financial management federal requirements outlined in
the 2 CFR 200 and 45 CFR 75?
Yes No
If yes, please explain:
PART IV: FEDERAL PROGRAMS
1. Was the audit submitted timely to Federal Audit Clearinghouse? Yes No
If no, please explain: Note: Audits are to be completed within 9 months of the end of the subrecipient‘s audit period
2. Does the SEFA include EHSD as a pass-through entity, the contract number(s), AL(s) and Federal
Subaward(s): Yes No
3. Did the auditee qualify as a low-risk auditee? Yes No
4. Did the auditee have prior or current year audit findings in Federal programs funded by other
entities than EHSD? Yes No
5. Is a material weakness(es) disclosed in internal control over major Federal programs?
6. Is a significant deficiency(ies) disclosed in internal control over major Federal programs?
7. Type of audit report issued on compliance for major programs:
Mark either:
Unmodified Opinion
Qualified opinion
Adverse opinion
Disclaimer of opinion
8. Were Prior Audit Findings related to direct funding shown in the Summary Schedule of Prior Au-
dit Findings? Yes No N/A if entity had no prior audit findings in previous
years
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FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 97
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 12
9. Does the audit include a summary schedule of prior audit findings with corrective action plan?
Yes No N/A if entity had no prior audit findings in previous
years
10. Does the audit include current year audit findings with a corrective action plan? Yes
No
11. If prior or current year audit findings are present, check compliance requirement(s) that apply to
audit findings:
Activities Allowed or Unallowed
Allowable costs/cost principles
Cash management
Davis-Bacon Act
Eligibility
Equipment and real property management
Matching, level of effort, earmarking
Period of availability of Federal funds
Procurement and suspension and debarment
Program income
Real property acquisition and relocation assistance
Reporting
Subrecipient monitoring
Special tests and provisions
Other
12. Do any of the prior or current year audit findings reveal questioned costs? Yes No
If yes, how much? ________ If finding directly related to EHSD, did the entity repay EHSD?
________
If questioned costs exist and entity has not repaid EHSD, follow 2 CFR 200.xxx to proceed with
issuing a management decision letter.
13. Do any of the prior or current year audit findings reveal significant instances of abuse such as
fraud? Yes No
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 98
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 98
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 13
APPENDIX 13: MANAGEMENT DECISION TEMPLATE
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 99
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 99
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 13
[Sample
Audit Transmittal Letter (for Comment Purposes)
Send this letter to request additional information]
Date
Address:
Re: (Auditee) Audit Report Number
Dated:
Period:
Dear (Name of Fiscal Contact):
Employment of Human and Services Department (EHSD) has examined the results of the Single Audit of the (Sub-
recipient), issued by (Name of Firm), dated ________, for the year ended June 30, 20XX.
The audit report on pages _________ cites questioned costs of $______ and on pages _______ cites _______ ad-
ministrative findings. At this time, EHSD is extending to (Name of Subrecipient) 30 days from receipt of this letter
to submit comments and/or documentation relative to the above questioned costs and administrative findings.
At the conclusion of the 30-day response period, an Initial Findings and Determination will be issued by this office.
Should you have any questions regarding this report, please contact _______ at __________.
Sincerely,
Name
Fiscal Officer
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 100
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 100
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 13
[Sample
Initial Determination Transmittal Letter
Send after Audit Transmittal Letter]
Date
Address:
Dear Mr. /Ms.:
This is in reference to the audit of (name of program) operated by the (Auditee). The Audit report contains (se-
lect):
• Questioned costs and administrative findings
• Administrative findings but no questioned costs
• Questioned costs in the amount of $__________
Enclosed is my Initial Determination on the audit findings summarized as follows:
Audit Report Number: (if applicable)
Audit Period:
Amount Questioned:
Amount Allowed:
Amount Disallowed:
Number of Administrative Findings:
Number of Uncorrected Administrative Findings:
The enclosed Initial Determination explains the reasons for the determinations to (select as appropriate):
• Allow or disallow costs
• Require administrative corrective action
• Allow or disallow costs and require administrative corrective actions
This notification provides (Auditee) with the opportunity to resolve the audit findings informally with the Employ-
ment and Human Services Department (EHSD) within ___ days from the date this letter and Initial Determination.
A Final Determination will be issued upon expiration of the ___ day informal resolution period.
If you wish to begin informal resolution discussions, please contact __________ of my staff at (Telephone number)
immediately upon receipt of this letter.
Sincerely,
Name
Fiscal Officer
[Enclose “Sample Management Decision Attachment”]
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 101
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 101
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 13
[Sample
Sample Management Decision Attachment
Findings and Determination Format. Attach to “Initial Determination Transmittal Letter”
(May be used as attachment for both Initial and Final Determinations)]
Date
Subject: Initial (Final) Determination
References: (Name of Subrecipient) Audit
Audit Number:
Audit Period Amount:
Questioned Amount:
Allowed Amount:
Disallowed Amount:
Amount Subject to Debt Collection (for Final Determination only):
Number of Administrative Findings:
Introduction: This is the Initial Determination on the resolution of (select):
• Questioned costs and administrative findings
• Administrative findings
• Questioned costs
Recommendations pertained to the EHSD programs are contained in the above referenced audit. These programs are
administered by the (Subrecipient). The audit was performed by (Audit Firm) pursuant to the provision of Title 2
Code of Federal Regulations §200.501 (Audit Requirements) and issued on (Date).
The audit report (select):
• Questioned $___ costs
• Identified ___administrative/procedural weakness(es)
• Questioned $___ in cost and identified ___administrative/procedural weakness(es).
The (Subrecipient’s) response to the audit report was taken into consideration in the preparation of this (Initial/Fi-
nal ) determination.
Finding Number
(Format/Content) The order of findings should correspond to the order in the audit report with administrative find-
ings listed first and questioned costs findings listed second. Findings contain the following:
• Amount and nature of the questioned cost and nature of the administrative finding
• Citation of appropriate regulation, circular, issuance, or agreements that were violated
• Appropriate explanatory information, including any subrecipient’s attempt to support cost or administrative
deficiencies
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 102
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 102
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 13
Determination
(Format/Content) The determination should include:
• Basis upon which the auditee’s response was accepted or rejected
• Precise statement as to whether questioned costs are allowed or disallowed (if appropriate)
• Precise statement as to whether or not the finding (administrative) is corrected.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 103
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 103
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
APPENDIX 14: CORRECTIVE ACTION LETTER TEMPLATE
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 104
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 104
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
[Sample
Final Determination Transmittal Letter
Disallowed Costs and Uncorrected Administrative Findings]
Date
Reference: Initial Determination Dated:
Address of Subrecipient:
Dear Ms./Mr.:
This is in reference to the recent Initial Determination on the audit of the Employment and Human Service Depart-
ment (EHSD) program subcontracted to [name of Subrecipient]. The Initial Determination was issued on the date
referenced above.
The audit report contains questioned costs and administrative findings. Enclosed is my Final Determination on the
audit findings summarized as follows:
Audit Report Number:
Audit Period:
Amount Questioned:
Amount Allowed:
Amount Disallowed:
Amount Subject to Debt Collection:
Number of Administrative Findings:
Number of Uncorrected Administrative Findings:
(Add the following bolded sections if costs have been disallowed)
The Final Determination, which is based on all the information available as of the date of this letter, establishes
a debt owed to the_____in the amount of $ . You are hereby requested to pay this amount by sending a
cashier’s check, drawn on non-Federal funds and payable to the___________, to:
(Name and Address)
In accordance with the (policy affecting debts – look up) interest on this debt shall accrue from the date of this
letter. Interest shall be charged at the (look up) rate prevailing on that date. If the debt is paid before it becomes
delinquent, which is (look up) days after the date of this letter, interest shall be waived.
Failure to honor this demand for repayment will result in collection actions being taken pursuant to (look up).
Delinquent debts that remain outstanding will, in some cases, jeopardize your eligibility for receipt of Federal
funds and become the basis for recommending enforced collection through litigation by the State .
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 105
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 105
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
Corrective action is required to address the administrative findings. Uncorrected administrative findings are
tracked until effective corrective action is implemented or other resolution occurs which meets the approval of
the EHSD. Your agency should address the remaining uncorrected issues by developing and implementing the cor-
rective actions needed. Periodic progress reports to EHSD are due on the first of each month until all findings are
corrected.
In accordance with 2 CFR 200.521, your agency may initiate an administrative appeal of by filing a written request
for hearing with the EHSD within 10 working days of receipt of this Final Determination. The request should state
your agency’s reasons for disputing the determinations.
A copy of the Final Determination should accompany your request for a hearing and should state specifically
those sections of the determination upon which a hearing is requested. Copies of the request for an administra-
tive appeal should be provided to this office.
In the event that no administrative hearing is timely requested, the debt herein established becomes a civil claim
of the State of (Awarding Entity). However, in the event that such a hearing is requested and granted, debt collec-
tion actions will be suspended, and no interest or other sanctions will be charged or imposed. If, however, the
case is dismissed because the appeal request was untimely, interest will be charged retroactively as though an
appeal had never been requested.
Copies of the Final Determination are being provided to .
Sincerely,
Name
Fiscal Officer
[Attach Final Determination]
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 106
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 106
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
[Sample
Final Determination Transmittal Letter
Uncorrected Administrative Findings]
Date
Reference: Initial Determination Dated:
Address of Subrecipient:
Dear Ms. /Mr.:
This is in reference to the recent Initial Determination on the audit of the Employment and Human Service Depart-
ment (EHSD) program subcontracted to [name of Subrecipient]. The Initial Determination was issued on the date
referenced above.
The audit report contains administrative findings. No costs were questioned. Enclosed is my Final Determination
on the audit findings summarized as follows:
Audit Report Number:
Audit Period:
Questioned Costs: none
Number of Administrative Findings:
Number of Uncorrected Administrative Findings:
Corrective action is required to address the administrative findings. Uncorrected administrative findings are
tracked until effective corrective action is implemented or other resolution occurs which meets the approval of
the EHSD.
Your (Agency)(Organization) should address the remaining uncorrected issues by developing and implementing
the corrective actions needed. Progress reports to EHSD are due on the first of each month until all findings are
corrected.
In accordance with 2 CFR 200.521, your agency may initiate an administrative appeal of EHSD related issues by
filing a written request for a hearing with the _______________ within ___ working days of receipt of this Final
Determination. The request should state your agency’s reasons for disputing the determinations.
This Final Determination is subject to review and concurrence by the EHSD. Copies of the request for administra-
tive appeal should be provided to this office and to ________
Sincerely,
Name
Fiscal Officer
[Attach Final Determination]
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 107
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 107
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
[Sample
Sample Management Decision Attachment
Findings and Determination Format. Attach to “Final Determination Letters.”
(May be used as attachment for both Initial and Final Determinations)]
Date
Subject: Initial (Final) Determination
References: (Name of Subrecipient) Audit
Audit Number:
Audit Period Amount:
Questioned Amount:
Allowed Amount:
Disallowed Amount:
Amount Subject to Debt Collection (for Final Determination only):
Number of Administrative Findings:
Introduction: This is the Initial Determination on the resolution of (select):
• Questioned costs and administrative findings
• Administrative findings
• Questioned costs
Recommendations pertained to the EHSD programs are contained in the above referenced audit. These programs are
administered by the (Subrecipient). The audit was performed by (Audit Firm) pursuant to the provision of Title 2
Code of Federal Regulations §200.501 (Audit Requirements) and issued on (Date).
The audit report (select):
• Questioned $___ costs
• Identified ___administrative/procedural weakness(es)
• Questioned $___ in cost and identified ___administrative/procedural weakness(es).
The (Subrecipient’s) response to the audit report was taken into consideration in the preparation of this (Initial/Fi-
nal) determination.
Finding Number
(Format/Content) The order of findings should correspond to the order in the audit report with administrative find-
ings listed first and questioned costs findings listed second. Findings contain the following:
• Amount and nature of the questioned cost and nature of the administrative finding
• Citation of appropriate regulation, circular, issuance, or agreements that were violated
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 108
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 108
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 14
• Appropriate explanatory information, including any subrecipient’s attempt to support cost or administrative
deficiencies
Determination
(Format/Content) The determination should include:
• Basis upon which the auditee’s response was accepted or rejected
• Precise statement as to whether questioned costs are allowed or disallowed (if appropriate)
• Precise statement as to whether or not the finding (administrative) is corrected
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 109
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 109
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
APPENDIX 15: COMMUNITY SERVICE BUREAU – SELF-MONITORING TOOLS
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 110
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 110
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
EHSD
Community Service Bureau - Self-Monitoring
Monitoring and Implementing Fiscal Infrastructure
INTRODUCTION
As a recipient of federal and state awards, EHSD is responsible for establishing a self-monitoring
policy per 45 CFR Part 75.303(c). Initial monitoring will take place quarterly and semi-annually
thereafter. Compliance assessments will be conducted to ensure:
• Compliance with statutory requirements
• Review of internal checks/controls
• Review of financial documents
• Review of business practices, processes and policies
45 CFR Part 75.303 Internal controls.
The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides rea-
sonable assurance that the non-Federal entity is managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award. These in-
ternal controls should be in compliance with guidance in “Standards for Internal Control in the
Federal Government,” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
(b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal
awards.
(c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the
terms and conditions of Federal awards.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 111
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 111
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
(d) Take prompt action when instances of noncompliance are identified including noncompli-
ance identified in audit findings.
(e) Take reasonable measures to safeguard protected personally identifiable information and
other information the HHS awarding agency or pass-through entity designates as sensitive or
the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and
tribal laws regarding privacy and obligations of confidentiality.
EHSD’s self-monitoring will adhere to the following Head Start regulation:
Head Start Performance Standard - 1302.102(b) Achieving program goals.
Monitoring program performance. (1) Ongoing compliance oversight and correction. In order to
ensure effective ongoing oversight and correction, a program must establish and implement a
system of ongoing oversight that ensures effective implementation of the program performance
standards, including ensuring child safety, and other applicable federal regulations as described
in this part, and must:
(i) Collect and use data to inform this process;
(ii) Correct quality and compliance issues immediately, or as quickly as possible;
(iii) Work with the governing body and the policy council to address issues during the ongoing
oversight and correction process and during federal oversight; and,
(iv) Implement procedures that prevent recurrence of previous quality and compliance issues, in-
cluding previously identified deficiencies, safety incidents, and audit findings.
EHSD Monitoring Process
Potential control weaknesses, policy or procedural violations, other areas of concern will be
identified and discussed with EHSD management. Throughout the self-monitoring, any observa-
tions, identified issues and associated risks are discussed with management. The Fiscal Compli-
ance Accountant will present management with their findings and recommendations.
A Compliance Assessment of EHSD’s programs will be prepared. EHSD’s Fiscal Compliance
Unit will conduct the assessment. In accordance with the requirements of the Fiscal Compliance
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 112
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 112
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
Accountant’s area of responsibility – Monitoring and Detection of noncompliance with fiscal re-
quirements for internal and county policies, funding agency regulations and requirements, adher-
ence to GAAP, proper use of negotiable items, appropriateness of claimed costs versus audited
or documented costs, and the impact and validity of cost.
The monitoring activities must include at least:
1. Reviewing financial reports prepared by EHSD. Review
https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-75/subpart-D/subject-
group-ECFR911e5e1a30bfbcb/section-75.305
2. Following-up and ensuring that the recipient takes timely and appropriate action on all defi-
ciencies pertaining to the Federal award provided to the recipient from program sponsors
through audits, on-site reviews, and other means.
3. Issuing a report of review findings pertaining to the Federal award provided to the recipient.
4. Depending upon the FCA assessment of risk posed by the recipient, the following monitoring
tools may be useful for EHSD to ensure proper accountability of the Federal award:
5. Providing recipients with training and technical assistance on fiscal-related matters;
6. Performing on-site reviews or desk review of the recipient's fiscal operations.
At least quarterly, other areas, like administrative cost, non-federal share (NFS), cost allocation
and required reporting should be reviewed. Ensure all required reports are being done when due
and are accurate and submitted to the appropriate agencies/entities like the Payment Management
System (PMS), Board and Policy Council.
Checklist to Review Budgeted Costs for Allowability, Allocability and Reasonableness
This Checklist is intended to assist the Fiscal Compliance Accountant with reviewing the recip-
ient budget and making a determination on whether budgeted costs are allowable, allocable and
reasonable to operate the program per 45 CFR Part 75.407. See Appendix 16 for EHSD’s
Process for Charging of Costs to Head Start.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 113
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 113
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
References:
• Title 2 - Code of Federal Regulations, Part 200, Grants and Agreements;
• Title 45 - Code of Federal Regulations, Public Welfare;
• Title 29 - Code of Federal Regulations, Labor;
• Federal Acquisition Regulations (FAR) Part 31, Cost Principles and Procedures for Commercial Entities; • Federal
Acquisition Regulations (FAR) Part 48, Cost Accounting Standards for Commercial Entities; and
• Other applicable Title(s) as indicated in grant agreement(s).
We strongly encourage the reader to review the applicability and exceptions sections found in 2 CFR 200.101 and 2 CFR
200.102 when making a determination on the applicability of the various CFR rules.
Determination Factors Yes √ No √
1. Are the budgeted costs necessary and reasonable?
2. Are the budgeted costs allocable to the Federal award?
3. Are the budgeted costs allowable to the Federal award? Provide me with
samples of budgeted costs and the supporting documentation. Explain how al-
lowability was determined.
4. Was there a cost allocation plan or description of the cost allocation methodol-
ogy submitted if common costs such as rent are allocated to the Federal?
5. If a cost allocation plan or description of the cost allocation methodology was
submitted, is the methodology to distribute common cost reasonable?
6. If there is a budgeted indirect cost rate:
a. Was a Federally approved indirect rate submitted?
b. Did the entity include an indirect cost using the de minimis rate?
Grant Number:
Program Name:
Date: Prepared By:
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 114
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 114
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
7. Was sufficient information provided to determine whether costs are correctly al-
located to each budget category (for example: Personnel cost vs Participant
cost)?
8. Do line items add up correctly?
9. Were budget calculations verified for accuracy?
10. Is there a budget narrative included?
Comments:
INTERNAL CONTROL QUESTIONNAIRE
40. Which method of accounting do you use?
Accrual
Modified Accrual
Cash
41. Electronic modules and journals used in Accounting System:
General ledger
Cash receipt journal
Cash disbursement journal
Payroll register
Timesheet
A/R ledger
A/P ledger
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 115
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 115
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
Cost Allocation
Fixed Assets
Human Resources
42. Name of accounting system(software) used:
43. Does your financial management system provide records that can identify the source and ap-
plication of funds for award supported activities, and track expenditures by project number
(Federal award) and against budgeted line items?
Yes No
If no, please explain.
44. List the names of the employees performing the following functions:
Activity Employee (First and Last Name)
Cashier (receiving payments)
Opening Mail
Restrictively endorsing
checks
Preparing deposits
Verifying daily receipts
Entering daily receipts
Reconciling bank accounts
Payroll
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 116
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 116
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
Activity Employee (First and Last Name)
RFI/RFP
Contractor’s Qualifica-
tion/Scoring/Contract Award
Demand/Invoice Review
Demand/Invoice Approval
Desk Review
Monitoring
45. Is EHSD management provided with regular updates on financial status of the organization
and specific Federal awards? Yes No
If no, explain:
46. Are the copies of the updates provided available upon request? Yes No
47. Are there written procedures for:
If yes, provide a copy of
Inventory Controls - 45 CFR Part 75.320 Yes No
• Provide me with a copy of your inventory list-
ing to verify assets are recorded per 45 CFR
Part 75.320.
• Are annual SF-428 submitted to ACF? Provide
me with a copy of the last report submitted.
Yes No
• How often are physical inventory done?
• Verify physical inventories are per 45 CFR Part
75.320.
Yes No
Accounting Policies - 45 CFR 75.403.400 Yes No
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
Purchasing guidelines - 45 CFR Part 75.327h, 45 CFR Part 75.328 Yes No
48. Provide a copy of the personnel policy manual. Do you have a formal, written personnel pol-
icy that addresses:
Pay Rates and Benefits - 45 CFR Part 75.430,75.431 Yes No
Provide me with the last two months leave accrual and
usage report. Is there a written policy on payment in
lieu of vacation? Please provide a copy.
Yes No
Time and Attendance Yes No
Leave Yes No
Conflict of Interest - 45 CFR Part 75.327(c) (1) Yes No
49. With respect to the conflict of interest provision of the contract, are there any situations,
which have not previously been disclosed? Yes No
If yes, please explain:
50. Was the organization a party to a business transaction with a family member of a current or
former officer, director, trustee, or key employee? Yes No
51. Is there a separate bank account for payroll? Yes No
52. Do you outsource your payroll? Yes No
Explain your payroll process:
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
53. Are the payroll checks signed by someone independent of the payroll clerk? Yes
No
Who?
If not, why?
54. Provide a narrative description of your cost allocation plan.
e) How do you track and control time spent on different activities to ensure that time and
efforts are billable to the funding source receiving the benefit(s)?
Describe:
f) How do you allocate labor/non-labor cost not directly associated to a program?
Describe:
g) How do you allocate your facilities costs?
Describe:
h) How do you allocate your general office expenses?
Describe:
55. Do you have a negotiated federally approved indirect cost rate?
Yes No
If yes, please provide the following information:
• Name of the cognizant agency:
• Provisional rate:
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
• Definition of the base:
Provide a copy of your federally approved provisional indirect cost rate agreement.
56. What is the reconciliation process for the bank accounts?
Describe:
57. What is the process for handling money/donations on-site?
Describe:
58. Who signs the checks and is there a double endorsement?
Describe:
59. Please describe the method used to support labor and benefit charges.
Describe:
60. Do you receive other sources of income to operate your program? Yes No
If yes, please list:
61. How is your financial audit funded (if required) pursuant to contract obligations?
Describe:
62. In your Single Audit, are Federal award funds paid to EHSD listed in the Schedule of Federal
Awards by contract number and Assistance Listing number?
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APPENDIX 15
Yes No Not applicable
If no, please explain:
63. Do you Cash Match/In-Kind Match for the funding? Yes No
If so, what is the source of the match? (Example: volunteer hours calculated by market
value)
Describe:
64. Do you use any other Federal funding source as match for this award? Yes No
Describe:
65. Do you use EHSD’s other award funds as match for any other contract? Yes No
If yes, please explain:
66. Explain your asset control model. How do you track inventory purchased by the award
funds?
Describe:
67. Describe your purchasing policy and practice. (How is a vendor selected? Bidding, small
business enterprise, etc.)
Describe:
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APPENDIX 15
68. Explain your travel policy as related to Federal award funds.
Describe:
69. At any time, has there been a security breach including wrongful access, inspection, use or
disclosure of confidential information at your agency? Yes No
If yes, please explain the nature of the breach and your process to mitigate:
70. Do you subcontract any of the EHSD awarded funds? Yes No
If yes, what type of monitoring procedure do you conduct?
71. What is the reconciliation process for the grant award? Please walk me through the process
and provide me with the most recent reconciliation.
Describe:
Comments
Monitoring Plan
Demand/Invoice Review
The purpose of the review is to ensure that financial reports (demands) include proper documen-
tation, support, cost are allowable, unallowable costs are not charged to Head Start, accrued lia-
bilities are supported, and have the necessary level of approvals, program and fiscal.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
In cases where unresolved non-compliance issues by recipients are detected during the fiscal
monitoring or other means, the Fiscal Compliance Accountant will review the monthly demand
as needed until recipient resolves the non-compliance issues.
Internal Control Review - 45 CFR Part 75.320 - EHSD controls financial management risks
with effective internal controls. EHSD policies and procedures control the access and use of fi-
nancial resources.
Contracts Review – RFI/RFPs and contracts are reviewed for vendor’s qualification and adher-
ence to Head Start – 45 CFR Part 75.327(h) General procurement standards and 45 CFR Part
75.328 Competition.
Verify Special conditions reference applicable Code of Regulations specific to Head Start.
Concerns/Areas of Non-Compliance
Personnel – Compensation and benefits review – 45 CFR Part 75.430 and 45 CFR Part 75.431
Concerns/Areas of Non-Compliance
Quarterly report review – Expenditure reports
Concerns/Areas of Non-Compliance
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
Budget review – Budgeted award vs Actual and Projections through the award date
Concerns/Areas of Non-Compliance
Conflict of interest policy - 45 CFR Part 75.327(c)(1) in its entirety in the Delegate’s Contract
Special Conditions and Department’s Policies
Concerns/Areas of Non-Compliance
Capital Asset Inventory - 45 CFR Part 75.320
Concerns/Areas of Non-Compliance
EHSD’s financial management system provides for effective control over and accountability for
all funds, property, and other assets.
The grantee complies with application, prior approval, and reporting requirements for facilities
Concerns/Areas of Non-Compliance
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DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 15
COMMENTS
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 16
APPENDIX 16: EHSD PROCESS FOR CHARGING COSTS TO HEAD START
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 16
I. GENERAL:
This Section sets forth the Employment and Human Services Department (EHSD) procedures
for charging of costs to Head Start Federal Awards.
Employment and Human Services Department (EHSD) charges costs that are reasonable, al-
lowable, and allocable to a federal award directly or indirectly. All unallowable costs shall be
appropriately segregated from allowable costs in the general ledger in order to assure that un-
allowable costs are not charged to federal awards.
II. REFERENCE:
• 45 CFR Part 75 Subpart E, Cost Principles
• 45 CFR Part 75.421 – 476
• 45 CFR Part 75.407
• 45 CFR Part 75.402 – 407 Basic Considerations
• 45 CFR Part 75.413(a)
• 45 CFR Part 75.320
• SF-428-A Tangible Personal Property Report
• SF-428-C Disposition Report/Request
III. POLICY:
A. Segregating Unallowable from Allowable Costs
The following steps shall be taken to identify and segregate costs that are allowable and unal-
lowable with respect to each federal award:
1. The budget and grant or contract for each award shall be reviewed for costs specifi-
cally allowable or unallowable.
2. Fiscal personnel shall be familiar with the allowability of costs provisions of 45 CFR
Part 75 Subpart E, Cost Principles particularly:
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 16
a. The list of specifically unallowable costs found in 45 CFR Part 75.421 – 476,
Selected Items of Cost, such as alcoholic beverages, bad debts, contri-
butions, fines and penalties, lobbying, etc.
b. Those costs requiring advance approval from federal agencies in order to be
allowable in accordance with 45 CFR Part 75.407, Prior Written Approval,
such as participant support costs, equipment purchases, etc.
3. No costs shall be charged directly to any federal award until the cost has been deter-
mined to be allowable under the terms of the award and/or 45 CFR Part 75 Subpart E,
Cost Principles.
4. For each federal award, an appropriate set of general ledger accounts (or account seg-
ments) shall be established in the chart of accounts to reflect the categories of allowa-
ble costs identified in the award or the award budget.
5. All items of miscellaneous income or credits, including the subsequent write-offs of
uncashed checks, rebates, refunds, and similar items, shall be reflected for grant ac-
counting purposes as reductions in allowable expenditures if the credit relates to
charges that were originally charged to a federal award or to activity associated with a
federal award. The reduction in expenditures shall be reflected in the year in which the
credit is received (i.e., if the purchase that results in the credit took place in a prior pe-
riod, the prior period shall not be amended for the credit).
B. Criteria for Allowability
All costs must meet the following criteria from 45 CFR Part 75.402 – 407, Basic Considera-
tions, in order to be treated as allowable direct or indirect costs under a federal award:
1. The cost must be “reasonable” for the performance of the award, considering the fol-
lowing factors:
a. Whether the cost is of a type that is generally considered as being neces-
sary for the operation of EHSD or the performance of the award.
b. Restraints imposed by such factors as generally accepted sound business
practices, arm’s length bargaining, federal and state laws and regulations, and
the terms and conditions of the award.
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APPENDIX 16
c. Whether the individuals concerned acted with prudence in the circum-
stances.
d. Consistency with established policies and procedures of Contra Costa
County, deviations from which could unjustifiably increase the costs of the
award.
2. The cost must be “allocable” to an award by meeting one of the following criteria:
a. The cost is incurred specifically for a federal award,
b. The cost benefits both the federal award and other work and can be dis-
tributed in reasonable proportion to the benefits received, or
c. The cost is necessary to the overall operation of EHSD, except where a direct
relationship to any particular program or group of programs cannot be
demonstrated.
3. The cost must conform to any limitations or exclusions of 45 CFR Part 75 Subpart E,
Cost Principles, or the federal award itself.
4. Treatment of costs must be consistent with policies and procedures that apply to both
federally financed activities and other activities of EHSD.
5. Costs must be consistently treated over time.
6. The cost must be determined in accordance with generally accepted accounting princi-
ples (GAAP).
7. Costs may not be included as a cost of any other federally financed program in the cur-
rent or prior periods.
8. The cost must be adequately documented.
C. Direct Costs
Direct costs are those costs that can be identified specifically with a particular final cost ob-
jective, such as a Federal Award, or other internally or externally funded activity, or
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APPENDIX 16
that can be directly assigned to such activities relatively easily with a high degree of accuracy
EHSD identifies and charges these costs exclusively to each award or program. (45 CFR Part
75.413(a))
Each Demand shall be coded with the appropriate account number reflecting which program
received direct benefit from the expenditure. Demands are approved by the appropriate pro-
ject director, reviewed by Fiscal and approved by the Head Start Accountant or DFO, or CFO
for payment issuance.
Time sheets are also submitted on a regular basis, reflecting employees' work and which pro-
grams directly benefited from their effort. Time sheets shall serve as the basis for charging
salaries directly to federal awards and nonfederal functions.
Equipment purchased for exclusive use on a federal award and reimbursed by a federal
agency shall be accounted for as a direct cost of that award (i.e., such equipment shall not be
capitalized and depreciated for grant purposes, but will be capitalized and depreciated at year-
end for financial statement purposes).
D.Indirect Cost Rate
EHSD maintains an annual indirect cost budget. Each year a new indirect cost budget is pre-
pared and submitted to Head Start cognizant agency for approval. The approved indirect cost
rate is used when determining the overhead applied to each federal award and major function.
EHSD’s process for developing and submitting its indirect cost proposal is:
1. Completion of the Indirect Cost Proposal (ICP) checklist.
2. Preparation of Indirect Cost Rate Proposal Reconciliation to prior year audit report.
The Indirect Cost Proposal with the required supporting information must be submitted to the
Department of Health & Human Services Division of Cost Allocation Western Field Office
within six months of fiscal year-end.
E.Description of Inventory
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APPENDIX 16
EHSD maintains an inventory of materials used for administration, and programs. Examples
of such items include, but are not limited to:
•Computers, Laptops, and related technology
•Portable Buildings
•Vans
•Furniture
•Equipment
F.Accounting for Inventory
EHSD records the purchase of capital equipment per Head Start regulations in 45 CFR 75 Part
75.320(d)(1).
Management requirements. Procedures for managing equipment (including replacement
equipment), whether acquired in whole or in part under a Federal award, until disposition
takes place will, as a minimum, meet the following requirements:
(1) Property records must be maintained that include a description of the property, a serial
number or other identification number, the source of funding for the property (including
the FAIN), who holds title, the acquisition date, and cost of the property, percentage of
Federal participation in the project costs for the Federal award under which the property
was acquired, the location, use and condition of the property, and any ultimate disposition
data including the date of disposal and sale price of the property.
(2) A physical inventory of the property must be taken and the results reconciled with the
property records at least once every two years.
(3) A control system must be developed to ensure adequate safeguards to prevent loss,
damage, or theft of the property. Any loss, damage, or theft must be investigated.
EHSD accounts for purchased inventory items at cost, using the FIFO method of valuation.
Unit cost shall be computed by adding freight, insurance and other shipping costs to the actual
cost of purchased inventory, dividing this total amount by the number of units purchased.
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APPENDIX 16
G. Physical Counts
A physical count of inventory will be performed at least every two years. Any inventory items
that appear damaged, obsolete or otherwise unable to be sold shall be excluded from the
counts. A detailed record of the physical count shall be kept by the individuals involved in
taking the inventory.
At the conclusion of the physical count, the inventory control log shall be extended by apply-
ing the most recent unit costs to the physical quantities of each item on hand. Form SF-428-A
Tangible Personal Property Report will be submitted annually to Head Start and include the
inventory control log. Any requests for asset disposition will be submitted on Form SF-428-C
Disposition Report/Request. Upon approval by ACF, balances shall be adjusted to reflect the
total inventory on hand as determined by the physical count.
H. PROPERTY AND EQUIPMENT
Capitalization Policy
Physical assets acquired with unit costs in excess of $5,000 are capitalized as property and
equipment in EHSD’s financial statements. Items with unit costs below this threshold shall be
expensed in the year purchased.
If an awarding agency requires a lower amount for equipment, EHSD will adhere to that dol-
lar amount only for that program or contract.
Capitalized property and equipment additions are accounted for at their historical cost and all
such assets, except land, are subject to depreciation over their estimated useful lives, as de-
scribed later.
Capitalized assets will be reported as expensed for grants if they were so budgeted in the grant
application. However, for EHSD financial statements, these assets will be capitalized and de-
preciated according to these policies.
Equipment Purchased with Federal Funds (45 CFR Part 75.320)
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APPENDIX 16
EHSD may occasionally purchase equipment and furniture that will be used exclusively on a
program funded by a federal agency. In addition to those policies on Asset Management de-
scribed earlier, equipment and furniture charged to federal awards will be subject to certain
additional policies as described below.
For purposes of federal award accounting and administration, "equipment" shall include all
assets with a unit cost equal to the lesser of $5,000 or the capitalization threshold utilized by
EHSD, described under Asset Management.
All purchases of “equipment” with federal funds shall be approved, in advance and in writing,
by the federal awarding agency. In addition, the following policies shall apply regarding
equipment purchased and charged to federal awards:
1. Adequate insurance coverage will be maintained with respect to equipment and furni-
ture charged to federal awards.
2. For equipment (or residual inventories of supplies) with a remaining per unit fair mar-
ket value of $5,000 or less at the conclusion of the award, EHSD shall retain the
equipment without any requirement for notifying the federal agency.
3. If the remaining per unit fair market value is $5,000 or more, EHSD shall gain a writ-
ten understanding with the federal agency regarding disposition of the equipment. This
understanding may involve returning the equipment to the federal agency, keeping the
equipment and compensating the federal agency, or selling the equipment and remit-
ting the proceeds, less allowable selling costs, to the federal agency. (45 CFR Part
75.320(e))
4. The Program grant manager shall determine whether a specific award with a federal
agency includes additional equipment requirements or thresholds and requirements
that differ from those described above.
5. A physical inventory of all equipment purchased with federal funds shall be performed
at least once every two years. The results of the physical inventory shall be reconciled
to the accounting records of and federal reports filed by EHSD.
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Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 16
Establishment and Maintenance of a Fixed Asset Listing
All capitalized property and equipment shall be recorded in a property log. This log shall in-
clude the following information with respect to each asset:
1. Date of acquisition
2. Cost
3. Description (including color, model, and serial number or other identification number)
4. Source of the equipment, including the federal award number, if applicable
5. Whether the title vests in CAP or the federal government
6. Information to calculate the federal share of the cost of the equipment, if applicable
7. Location, use, and condition
8. Depreciation method
9. Estimated useful life
10. Ultimate disposition data including the date of disposal and sale price
A physical inventory of all assets capitalized under the preceding policies will be taken on
every two years. This physical inventory shall be reconciled to the property log and adjust-
ments made as necessary. All adjustments resulting from this reconciliation will be approved
by the CFO of the Fiscal Department.
Receipt of Newly-Purchased Equipment
At the time of arrival, all purchased equipment and furniture shall be examined for obvious
physical damage. If an asset appears damaged or is not in working order, it shall be returned
to the contractor immediately.
In addition, descriptions and quantities of assets per the packing slip or bill of lading shall be
compared to the assets delivered. Discrepancies should be resolved with the contractor imme-
diately.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 16
Depreciation and Useful Lives
All capitalized assets are maintained in the special property and equipment account group and
are not included as an operating expense. Property and equipment are depreciated over their
estimated useful lives using the straight-line method.
In the year of acquisition, depreciation is recorded based on the number of months the asset is
in service, counting the month of acquisition as a full month (Example: an asset purchased on
the 15th day of the fifth month shall have eight full months of depreciation (eight-twelfths of
one year) recorded for that year.)
Estimated useful lives of capitalized assets shall be determined by the head of the Fiscal De-
partment in conjunction with the department or employee that shall utilize the asset. The fol-
lowing is a list of the estimated useful lives of each category of fixed asset for depreciation
purposes:
Automobiles 5 years
Furniture and fixtures Up to 10 years
General office equipment 5 years
Computer hardware and peripherals 3–5 years
Computer software 2–3 years
Leased assets Life of lease
Leasehold improvements Remaining lease term
For accounting and interim financial reporting purposes, depreciation expense will be rec-
orded on an annual basis.
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Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
APPENDIX 17: EHSD DELEGATE ONSITE MONITORING TOOL
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EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Delegate Onsite Monitoring Tool
This monitoring tool can be adapted as needed by the user. Please line out the steps rather than
deleting them if they are not needed for the review you are conducting and provide a justification
in the comment section. Add steps as needed based on your preliminary review prior to your
monitoring visit.
Please complete the following section:
Subrecipient Name:
Subaward Number:
Subaward Amount:
Funding Sources and AL No.:
Analyst conducting the review: Date:
Subrecipient’s Fiscal Officer:
Before using this onsite monitoring tool, answer the following questions:
Pre-Onsite Monitoring Activities Questions: YES / NO
1. Was the Annual Subrecipient/Contractor Determination checklist com-
pleted?
Yes No
2. Was the determination made that the entity is a subrecipient? Yes No
3. Was the Single Audit Certification sent to the Subrecipient? Yes No
4. Did the subrecipient indicate on Single Audit Certification form that the
subrecipient entity is subject to 45 CFR 75 Subpart F - Single Audit Re-
quirements?
Yes No
5. If the answer is yes to 4, did EHSD receive the latest subrecipient single
audit and was the Single Audit Review checklist completed?
Yes No
6. Was the Annual Subrecipient Questionnaire sent to the subrecipient? Yes No
7. Were the subrecipient’s responses to the Annual Subrecipient Question-
naire and Single Audit Review Checklist used to complete the Risk Anal-
ysis Matrix?
Yes No
8. Was the subrecipient risk level assessed HIGH upon reviewing the risk
categories listed in the Risk Assessment Matrix?
Yes No
9. If the answer to 8 is no, was the subrecipient risk level assessed MOD-
ERATE and did the subrecipient have finding(s) in the previous EHSD
monitoring report or finding(s) in the prior year Single Audit?
Yes No
DEPARTMENTAL FISCAL
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ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 137
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Pre-Onsite Monitoring Activities Questions: YES/NO
10. Regardless of the answers to 8 and 9, the subrecipient is subject to quarterly
onsite monitoring. See monitoring Plan #4.
Yes No
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 138
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 138
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Onsite Review Planning Phase
A Steps NOTE: Document what was asked, response, list docu-
ments reviewed and state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Contact program analyst before notifying subrecipient
about the onsite monitoring review and obtain the follow-
ing information:
• Date of last program review or site visit
• Copy of report if subrecipient had program
findings or service concerns
• Copy of subrecipient corrective action plan and
timeline
2. Gain an understanding of the rules and regulations applica-
ble to the subrecipient Federal subawards:
• Obtain AL number and program name
• Obtain UEI number
• Review fiscal section of grant agreement, if
applicable
• Review contract special conditions
• Review Federal Cost Principles section in 2 CFR
200, 45 CFR 75 or other applicable CFRs
• Review applicable State guidance on fiscal
compliance
3. Gain an understanding of the subrecipient fiscal conditions
by reviewing the following documents:
• Latest subrecipient Single Audit and completed
Single Audit Review checklist
• Subrecipient’s responses to Annual
Subrecipient Questionnaire
• Completed Risk Assessment Matrix
• Annual contract budget
• Monthly Financial Reports (demands)
• Contract Budget v. Actual by line item Report
• Obtain and review payment history from the
Auditor-Controller’s Intranet site
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 139
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 139
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
A Steps NOTE: Document what was asked, response, list docu-
ments reviewed and state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
4. Review subrecipient submitted monthly and year-to-date
expenditures and determine type of costs to be reviewed
during on-site visit. Consider prior EHSD monitoring re-
sults, single audit findings and areas of risk identified dur-
ing preliminary review in determining
the selection of cost items.
Sample at least one monthly demand based on following
considerations:
•Dollar amount of demand relative to total
contract (subaward)
•Determine the major cost elements by calculat-
ing the percentage to total by cost element in
the subrecipient’s annual contract budget
•Major cost elements as measured by percentage
to total annual contract budget (i.e. salaries, facili-
ties and supportive services) represented on sam-
pled demand
•If prior monitoring or audit findings, attempt to
select a demand that will allow the monitor to as-
sess whether the corrective action plan was ade-
quately implemented
5. Inform subrecipient of onsite monitoring visit and request
list of items.
•Prepare and mail notification letter to subre-
cipient with a copy to program analyst
•Inform the subrecipient that the fiscal monitor
will review the responses/ statements to the An-
nual Subrecipient Questionnaire sent earlier dur-
ing the fiscal year. Cost items claimed on the
sampled monthly demand will be verified during
the onsite monitoring visit for allowability, alloca-
bility and reasonableness
•Attach to notification a request for items to be re-
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 140
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 140
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
A Steps NOTE: Document what was asked, response, list docu-
ments reviewed and state findings or results/conclusion if
no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
viewed before and during onsite monitoring Gen-
eral Items
o Cost Allocation Plan
o Indirect Cost Agreement, if applicable
o Chart of Accounts
o Personnel Manual
o Accounting Policies
o Purchasing Guidelines
o If responses to Annual Subrecipient
Questionnaire were incomplete (i.e.
org chart not provided) or unclear, re-
quest that the information be pro-
vided prior or during the onsite moni-
toring visit
For Monthly Sample Demand
o Detailed Expenditures and Revenue
Transaction Ledger
o Check Registers
o Payroll Registers
o Time Studies/Time Sheets
o Invoices and purchase orders/con-
tract
o Cancelled Checks or detailed bank
statement showing check numbers
o Travel Vouchers
o Property Inventory Control Listing, if
applicable
A Steps NOTE: Document what was asked, response, list documents
reviewed and state findings or results/conclusion if no find-
ings. Add
Comment(s) if Noncompliance is Detected or Improvements
are Needed
6. Review and evaluate documents received from subrecipient
in response to the request. Make a list of missing docu-
ments.
7. Prepare a list of questions for the entrance conference and
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 141
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 141
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
A Steps NOTE: Document what was asked, response, list documents
reviewed and state findings or results/conclusion if no find-
ings. Add
Comment(s) if Noncompliance is Detected or Improvements
are Needed
on-site visit that are tailored to the areas of risk identified
during the review of responses to Subrecipient Question-
naire and submitted documents.
Conflict of Interest
8. Review Conflict of Interest in the Subrecipient Contract Gen-
eral Conditions.
9. Verify if there is a modification of the Conflict of Interest
provisions in the Subrecipient Contract Special Conditions
Section. Review the additional language for compliance with
45 CFR Part 75.327(c) in its entirety.
10. Research the applicable Code of Federal Regulations on
Conflict of Interest for additional guidance.
11. Review subrecipient’s conflict of interest policy and verify if
the policy is in alignment with the Subrecipient Contract
General Conditions and Special Conditions, if applicable.
Other Steps as Needed
FFATA Reporting
As required by the Federal Accountability and Transparency Act of 2006 (FFATA), Federal agencies,
and non-federal agencies receiving federal funds, are required to report to the federal government
specific information associated with subrecipients of subawards (i.e., grants) over $30,000, as well as
executive compensation amounts for the five most highly compensated executives of your organiza-
tion should you meet certain threshold reporting requirements as listed below.
Executive Compensation Questions (see definitions on next page)
Place an X under
Yes or No
Our organization received 80 percent or more of its annual gross revenues from Federal procurement
contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as de-
fined at 2 CFR 170.320 (and subawards)
Yes No
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 142
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 142
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Your organization received $25,000,000 or more in annual gross revenues from federal procurement
contracts (and subcontracts), and Federal financial assistance subject to the Transparency Act (and
subawards).
Yes No
The public does NOT have access to information about the compensation of the executives through pe-
riodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C.
78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the public has
access to the compensation information, see the U.S. Security and Exchange Commission total com-
pensation filings at http://www.sec.gov./answers/execomp.htm.)
Yes No
If you answered yes to ALL three executive compensation questions above, complete the table below:
Names of 5 Mostly High Compensated Executives Compensation for Preceding Completed Fiscal
Year
1)
2)
3)
4)
5)
During Onsite Review Visit
Standard Questions of Head Start funded programs to en-
sure the seven (7) Findings under Internal Control are not re-
peated.
NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
Does the subrecipient have policies and procedures on in-ternal controls?
Does the subrecipient follow the policies and procedureson internal controls? (45 CFR Part 75.303)
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 143
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 143
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Standard Questions of Head Start funded programs to en-
sure the seven (7) Findings under Internal Control are not re-
peated.
NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1st Finding - Accruals not supported by documenta-
tion at year end.
•Are subrecipient accruals supported by
documentation, allowable and charged
to the correct budget year?
2nd Finding – Charging HS for insurance costs be-
longing on other programs.
•Are all costs charged to Head Start and
EHS applicable only to Head Start and
EHS and no other programs?
•Are there any journal entries indicating
transfer of costs out of Head Start to
Other programs?
3rd. Finding – conflict of Interest
•Have contracts awarded by subrecipient
been reviewed for conflict of interest?
4th Finding – Qualified Contractor
•Does the subrecipient ensure contractors
are qualified and not debarred?
5th Finding – Compensation:
•Are employees paid according to ap-
proved Payroll and Personnel records
and consistent with HR policies and pro-
cedures?
6th Finding – Vacation Accruals
•Are employees paid only up to the
agency approved vacation rollover
threshold?
7th Fixed Assets
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 144
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 144
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
Standard Questions of Head Start funded programs to en-
sure the seven (7) Findings under Internal Control are not re-
peated.
NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
•Does the subrecipient ensure they follow
45 CFR Part 75.320 and have an updated
inventory list?
B General Steps NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
1. Conduct entrance conference. Collect sign-in sheet with list
of attendees.
2. Meet with fiscal officer to go over contract monitoring
questionnaire and submitted documents. Clarify items as
needed and obtain the missing documents, if any, from the
requested document list.
3. Ask fiscal officer to describe the process in place for the fol-
lowing items:
•Preparation of monthly/quarterly invoice (de-
mand)
•Org chart in relation to accounting functions, in-
ternal control and signature authority
•Personnel costs billed to contract
o Time sheet completion and sign off
o Determination of cost centers for time
charges and cost allocation plan
o Payroll process from timesheet completion
to printing/ETF to posting of payroll to
ledger
o Employee benefits and payroll taxes
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 145
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 145
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
B General Steps NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
4. •Non-personnel costs billed to contract
o Accounts payable process from purchase au-
thorization (requisition/purchase order) to
processing vendor payment and issuing
checks/ETF
o Space cost billed to contract, including lease
agreement and cost allocation plan
o Vendor and sub-recipient agreement and is-
suance of payment
o Process for selecting vendors and sub- recipi-
ents
o Process for authorizing and reimbursing em-
ployee travel
5. •In-Kind/Cash Match reported to EHSD (only if the
contract requires a match)
o Valuation system for In-Kind services and do-
nated goods
o Maintenance of records system for In-Kind
services and donated goods
o Tracking system for reporting cash match
6. Obtain and review written accounting procedures for the
above items and pertinent policies (travel, purchasing).
7. Request supporting documentation for selected items of cost
from the sampled monthly/quarterly invoice (demand). Se-
lected items of cost may vary based on result of risk assess-
ment. See boxes below for additional details.
Conflict of Interest
8. Perform onsite interviews on a sample basis with various
management staff overseeing functions such as finance, pro-
curement and governance.
9. Identify potential risk and issues using the below sample of
questions.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 146
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 146
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
B General Steps NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
•Have any of the key executives or Board Members
been associated with other organizations in the past
with which you have a business relationship and, if
yes, what was the nature of those organizations and
relationships?
•Can you describe how you monitor Conflict of Interest
in your organization?
•Have managers at all levels expressed their commit-
ment to the policy?
•If you have a subrecipient under this contract, how do
you monitor conflict of interest?
•Is the policy easily accessible to everyone within the
organization and to external partners/vendors?
•Have managers and staff received adequate training
in how to manage and/or report conflicts of interest?
•Is conflict of interest policy and awareness incorpo-
rated into your recruitment, selection and procure-
ment processes?
How to Solve Conflict of Interest
10. Address conditions under which outside activities, relation-
ships, or financial interests are proper or improper; (accept-
ing gifts, disclosing confidential information, outside em-
ployment).
11. Outline how financial conflicts of interest may be ad-
dressed.
12. Identify when and how the subrecipient must provide dis-
closure, written notification, possible outside activities, rela-
tionships, or financial interests to EHSD.
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 147
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 147
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
B General Steps NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
13. Explain the consequences of non-disclosure may result in
additional conditions and could result in suspension or de-
barment.
14. Document and demonstrate compliance efforts.
Other Steps as Needed
C Selected Cost Item - Personnel cost NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or Im-
provements are Needed
1. Select one or two employees listed on invoice and compare
to org chart to ensure they are working on the programs
funded by the contract being monitored.
2. Obtain timesheet for each employee and trace cost center
code to chart of accounts. If hours worked by the selected
employee are pooled, compare the cost pool allocation
methodology from the subrecipient’s cost allocation to how
the hours were allocated to the benefiting programs. Verify
that the base of allocation is reasonable and adequately
supported by actual numbers.
3. Obtain payroll register and compare employee total salary
to documented salary in employee’s personnel file.
4. Compare check number on payroll register to bank state-
ment to verify that the check cleared. If the subrecipient
uses EFT, verify that the check number is on the positive
pay file submitted to the bank. Then verify that the total
amount from the positive pay file cleared the bank
per the bank statement.
DEPARTMENTAL FISCAL
POLICY
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SECTION: 25-130
PAGE NO.: 148
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 148
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
5.
Trace cost from payroll register to general ledger. Use time-
sheet to calculate cost center hours to-total hours ratio.
Apply ratio to employee salary from payroll register and
compare calculated amount to amount in the general
ledger for the cost center code designated for this contract.
This step may need to be modified depending on the sub-
recipient’s payroll process in place. The calculated amount
should match the general ledger and sampled
monthly invoice.
Other Steps as Needed per Risk Level
D Selected Cost Item - Non-personnel cost (space) NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Obtain total cost and square footage from lease agreement
and calculate monthly rent.
2. Request detailed ledger disclosing rent transaction and as-
sociated documentation supporting rent cost billed on
sampled monthly invoice.
3. Review A/P supporting documentation and verify that the
correct amount of payment was made to landlord listed
on lease agreement. Compare check number to bank
statement to verify that the check cleared.
4. Determine space allocation methodology from the subre-
cipient’s cost allocation plan.
5. Verify that the share of rent billed to the contract for the
sampled monthly invoice was appropriately allocated in ac-
cordance with the cost allocation plan. If cost allocation
plan is not provided (may result in an administrative find-
ing), verify that the share of rent cost billed to the contract
is reasonable based on a sound methodology. If methodol-
ogy is not sound or adequately supported by accounting
records/lease, this may result in a cost
disallowance.
Other Steps as Needed per Risk Level
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 149
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 149
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
D Selected Cost Item - Non-personnel cost (space) NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
E Selected Cost Item - Non-personnel cost (vendor/sub-recipient) NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting cost (i.e. office supplies,
contracted services) billed on sampled monthly invoice.
Documentation should include the following:
•Authorization to purchase (requisition, PO, etc.)
with appropriate signature in accordance with
organization’s signature authority.
•For contracted services, obtain a copy of the
contract to verify payment conditions.
•Price reasonableness.
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OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 150
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
• Indicator showing that the goods/services were
received and vendor invoice.
2. Verify that the goods/services purchased benefitted pro-
gram funded by contract being monitored and that the cost
is recorded in the appropriate cost center.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
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POLICY
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PAGE NO.: 151
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 151
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
F Selected Cost Item - Non-personnel cost (travel) NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Request detailed ledger disclosing transaction and associ-
ated documentation supporting travel cost billed on sam-
pled monthly invoice. Documentation should include the
following:
•Authorization to travel and travel reimbursement
form with appropriate signature in accordance with
organization’s signature authority.
•Travel receipts for hotel, airfare and other travel
cost. If organization uses per diem, verify that the
per diem does not exceed the federal per diem
schedule. If per diem is higher, an additional step
maybe necessary to determine reasonableness of
the per diem (not supported by receipt).
2. Verify that the cost is recorded in the appropriate cost cen-
ter.
3. Compare check number to bank statement to verify that
the check cleared. Verify that the check was made to the
appropriate party.
Other Steps as Needed per Risk Level
G Exit Conference and Other Items NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Make copies of evidence supporting findings, if any.
During the review, cross reference contract and CFR/OMB
references supporting findings, if any.
2. Conduct exit conference. Collect sign-in sheet with list of
attendees.
Inform attendees of potential administrative findings and
cost disallowance, if any.
3. Be prepared to write monitoring report.
Other Steps as Needed per Risk Level
DEPARTMENTAL FISCAL
POLICY
REPLACES: 07-08-2022
SECTION: 25-130
PAGE NO.: 152
ISSUED/REVISED: 01-01-03
FISCAL MONITORING
OF SUBRECIPIENT
SECTION: 25-130
PAGE NO.: 152
EFFECTIVE: 05-10-2023
DMCL #23-17
Contra Costa County Issued/Revised 05-10-2023
Employment and Human Services Distribution: 1,4,10,31,41,51,70
APPENDIX 17
G Exit Conference and Other Items NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
Post Activities after Onsite Review
H Exit Conference and Other Items NOTE: Document what was asked, response, list
documents reviewed and state findings or re-
sults/conclusion if no findings. Add
Comment(s) if Noncompliance is Detected or
Improvements are Needed
1. Write draft monitoring report within 10 days of the visit un-
less there are extenuating circumstances
2. Provide copy of draft monitoring report to Fiscal Officer or
his/her designee for review.
3. Finalize monitoring report and mail to subrecipient.
4. If findings are in monitoring report, request corrective ac-
tion plan with timetable.
5. Follow up with subrecipient on corrective action plan per
timetable and verify during the next annual monitoring that
is implemented.
6. File electronically monitoring documents and inform
Compliance Accountant of monitoring outcomes.
Other Steps as Needed per Risk Level
Contra Costa County
Employment & Human Services Department
Community Services Bureau
Cost Allocation Plan
Page 1 7/11/2023
Most childcare program costs are allocated based on funded slots. Program slots
(including partnerships) are placed on a grid by funding source.
COLLABORATION BETWEEN CHILD DEVELOPMENT & HEAD
START/EARLY HEAD START
Eligible children in certain classrooms are enrolled in both Head Start, Early Head Start,
Early Head Start Child Care Partnership and Child Development programs. This
partnership serves to:
1. Enhance existing services
2. Increase the number of Full-Day Full-Year days funded in State Pre-School
The collaboration between these programs requires a method of sharing program costs
that is both equitable and approved by both funding sources. At Contra Costa County,
accounting for these program slots has evolved into two fiscal models:
Comprehensive Services Model (State/Head Start and Early Head Start Programs)
CCTR & CSPP (Full-day) are full-day, full-year programs. Head Start and Early Head
Start provide an “umbrella” of additional services, including comprehensive services,
additional training resources, additional staff and/or resources,. In this model, all site and
classroom costs are charged to Child Development program. All cost of comprehensive
services applicable to Head Start are charged to Head Start. Comprehensive services
include but not limited to health, mental health, family services, etc.
Cost Allocation Model (Extended Services to Full Day ) (State Pre-School Programs,
Part-Day)
Eligible children are enrolled in both the Head Start and Child Development programs in
order to allow an increase in the number of full-day full-year slots funded. Costs are
allocated between Head Start and Child Development based on the service hours
provided by each program.
Under both models, costs of Comprehensive Services such as Mental Health, Family
Services and certain facilities, equipment and non-consumable supplies are not allocated
but are charged as direct costs to the Head Start and Early Head Start Grants.
Certain one time costs like renovation, building improvement, purchase of major
equipment, etc. are charged to Head Start with prior approval from ACF.
ALLOCATED COSTS
Site Costs:
ATTACHMENT H
Contra Costa County
Employment & Human Services Department
Community Services Bureau
Cost Allocation Plan
Page 2 7/11/2023
Site Supervisors, building occupancy charges, utilities, telephone and center supplies are
charged to the cost center for each site. Accountants allocate the costs based on the
funded slots at the site.
Room Costs:
Teachers and supplies are charged to the cost center for each room. Where rooms have
multiple funding sources, the accountants allocate those cost centers based on the funded
slots in that room.
Other Staff Charges:
Comprehensive Services staff charge their time to Head Start or Early Head Start
accordingly since they are part of the Comprehensive Services provided by Head Start
and Early Head Start.
Administrative Staff (including Assistant Directors) charge their time directly to Head
Start or Early Head Start admin cost centers.
Other positions charge actual time worked directly to the programs or to a cost center that
is then allocated to the programs based on funded slots (e.g. Child Care Food Program,
Facilities Management, etc.).
Child Care Food Program:
The meal reimbursement rates are determined by the USDA. Expenses are allocated
based on funded slots. Revenues are allocated based on the same monthly allocation
worksheet. CDE and Head Start funding cover the excess of expenditures over
reimbursements.
Administrative Charges:
Direct Admin charges are allocated from one cost center based on funded slots.
Indirect Admin charges and Community Services Bureau’s portion of the County
Overhead is allocated based on the approved County Indirect Cost Rate.
DIRECT PROGRAM CHARGES
Some costs are charged directly to one funding source and do not need to be allocated.
Some examples are:
1. Training (and related travel) targeted for a specific program
2. Equipment to be funded through a specific program
3. Facilities to be funded through a specific program
4. Allocated based on the number of staff