HECC did not report non-federal matching and Maintenance of Effort (MOE) expenditures in accordance with the requirements in WIOA.
States are required to provide, from non-federal sources, 25% of the total amount of funds expended for adult education and literacy activities in the State in order to meet the section 222 match requirement under WIOA. According to the Uniform Guidance, matching has several requirements, including being necessary and reasonable for accomplishment of program objectives and not being used as a contribution for other federal awards. In addition, WIOA and the Uniform Guidance have requirements for allowable expenditures and activities. Finally, the Uniform Guidance requires written procedures for managing federal grant and matching funds, including procedures to determine the allowability of costs.
In a review of the State’s PY 2019 and 2020 FFRs, HECC reported 85.71% and 87.11% match, respectively, which the State indicated came from local funds. HECC indicated that in addition to the Oregon Adult Basic Skills Title II Adult Education and Literacy Grant Policy Manual, HECC provided extensive training to local programs to ensure the programs were adhering to match requirements and also conducted monitoring for risk assessment and program improvement of selected local programs, in which fiscal monitoring periodically took place. However, in document reviews and interviews with State staff, the federal review team was unable to determine that HECC could verify that the matching funds reported by local providers to HECC were expended on allowable adult education activities.
HECC must adopt procedures to review expenditures to ensure compliance with matching and MOE requirements and train staff and local providers on the procedures. HECC must put in place procedures and appropriate tracking of cash and in-kind contributions from local programs for matching and MOE for the AEFLA program. In addition, HECC must review the recipient share expenditures reported on the PY 2022 final FFR and all subsequent reports to ensure compliance with matching and MOE requirements.
Sections 222(b) and 241(b) of WIOA; Uniform Guidance 2 CFR §§ 200.302, 200.306, and 200.400