ACTION BULLETINS (PY 2006)

AB - #64 Invoicing Process

AB - #64
Effective: Immediately


ACTION BULLETIN

Invoicing Process


TO: All Alameda County Workforce Investment Board (ACWIB) Contractors

DATE: December 22, 2006

SUBJECT: Invoicing Process


PURPOSE OF BULLETIN:
The purpose of this bulletin is to inform all ACWIB Contractors about amendments to the invoicing process to allow some flexibility in the timely reporting of expenditures and accruals of Workforce Investment Act (WIA) Title I funds.

CITATIONS:
WIB Consent Item V.A. – Recapture and Redistribution Policy, approved June 2003
Contract Exhibit F.A: General Conditions / Special Conditions Workforce Investment Act (WIA)
Workforce Investment Board (WIB) Action Item V.E. – One Stop Career Center Refunding Criteria for PY 2007-08, approved December 2006

BACKGROUND:
The State of California Workforce Investment Division (WID) requires ACWIB to report expenditures and accruals on a monthly basis, to confirm that WIA Title I funds are being expended appropriately according to funding stream plans and allocations.

The ACWIB Recapture and Redistribution Policy states “In order to meet the Local Workforce Investment Area’s (LWIA) overall expenditure plan for all WIA Formula Grants, the WIB will recapture under expenditures from all providers semi-annually based on a negotiated spending plan outlined in each contract. The recaptured funds will be redistributed according to a WIB approved priority list.” In order for Contractors to avoid recapture of funds, invoices must be submitted on a timely basis.

Currently, Contract Exhibit F.A. requires the “Contractor to submit an invoice by the fifth (5th) working day following the close of each month for all expenditures incurred under this contract for the prior month.”
Over time it has become apparent that this timeline is not always manageable for our Contractors, especially those whose fiscal agent is part of a larger organizational structure. In addition, official invoices are often delayed due to a lack of final contract, changes in accounting systems, etc. Therefore, ACWIB is extending the due date of invoices to the 15th working day of every month.

POLICY AND PROCEDURES:
Effective immediately, each Contractor will be required to submit expenditure information monthly using one of the following two options:

Option 1:
The Contractor will submit an invoice by the 15th working day of the month following the close of each month for all expenditures incurred under this contract for the prior month.

Option 1 is preferred.

Option 2:
a. Contractor will submit an estimate of expenditures, via email, by the 15th working day of the month, following the close of each month for all expenditures incurred under this contract for the prior month, AND

b. Contractor will submit an invoice by the 15th working day of the second month following the close of the month for which all expenditures incurred under this contract for the month.

Option 2 is offered to those contractors whose fiscal agent has difficulty in generating and submitting a monthly invoice.

The expenditure and accrual estimates will be tracked and reported by the Contractor. The ACWIB financial manager will provide tools and technical assistance to the Contractor so a tracking/reporting process can be set up, if requested.

Regardless of which invoicing option chosen, the Contract Exhibit F goes on to say that “Payment is expressly conditioned upon timely submission of said invoices. Submission of monthly invoices shall be for cumulative expenditures no greater than 110% of monthly cumulative plan. Exceptions to these limits may be granted, but in no case shall the sum of all reimbursed funds exceed the total contract amount.”

Corrective Action Procedures:
The invoicing option chosen will be tracked internally by the ACWIB financial manager and program operator program liaison and monitored for compliance during the annual fiscal monitoring.

To promote timely and accurate submission of expenditure information, ACWIB is initiating a corrective action process:

1. If the invoice process is missed the first month, the financial manager will send a reminder email, copying the program liaison. The Contractor will respond with an explanation for the late invoice.

2. If the invoice process is missed a second month, the financial manager will send a corrective action email. The Contractor will respond with an explanation for the late invoice.

3. If the invoice process is missed a third month, the Program Liaison will send a corrective action letter to the Contract signatory requiring a corrective action plan explaining how the invoicing process will be fixed to meet the deadlines.

4. If the invoice process is missed a fourth month, the Assistant Agency Director will send a corrective action letter to the Contract signatory stating that the Contractor will be put on official probation status. The invoicing problems must be corrected in order to pass the fiscal monitoring portion of the refunding criteria. The problem will be considered fixed when the invoice and/or estimate, if appropriate, are submitted on time for three consecutive months.

ACTION:
All Contractors must choose an invoicing option and notify the ACWIB financial manager. The invoicing process is effective immediately. The corrective action process will be implemented with the invoice due to ACWIB on Friday, January 19, 2007.

Please use the latest invoice form sent out in Information Bulletin #20 for Adults and Dislocated Workers and Information Bulletin #23 for Youth Providers.

INFORMATION AND INQUIRIES:
For information and inquiries please contact David Harkess, Financial Manager at (510) 259-3832 or by email at DHarkess@acgov.org