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Accounting and Financial Policies andProcedures ManualApproved and Published: February 2019IMPORTANT! This document contains important information about your rights, responsibilities and/or benefits. It iscritical that you understand the information in this document, and we will provide the information in your preferredlanguage at no cost to you. Call Kim Chapman (405) 275-7800 for assistance in the translation and understanding ofthe information in this document.¡IMPORTANTE! Este document contiene información sobre sus derechos, responsabilidades y/o beneficios. Esimportante que usted entienda la información en este documento. Nosotros le podemos ofrecer la información enel idioma de su preferencia sin costo para usted. Llame al Trini Rodriguez (405) 275-7800 para pedir asistencia entraducir y entender la información en este documento.Telephone Relay Service is available by dialing 711 or (800) 722-0353The Central Oklahoma Workforce Innovation Board (COWIB) is the policy and guidance board for the Workforce Oklahoma system inCentral Oklahoma. We are business leaders with a goal to establish a highly skilled, productive workforce in our 9-county area.The Central Oklahoma Workforce Innovation Board (COWIB) complies with WIOA’s Equal Opportunity and Nondiscrimination provisionswhich prohibit discrimination on the basis of race, color, religion, sex (including pregnancy, childbirth, and related medical conditions,transgender status, and gender identity), national origin (including limited English proficiency), age, disability, political affiliation or belief,or, the basis of citizenship status or participation in a WIOA Title-1 financially assisted program or activity.COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individuals with disabilities. Thiswas financed in whole or in part by fund from the US Dept. of Labor as administered by the Oklahoma Office of Workforce Development.http://www.cowib.org/
Accounting and Financial Policies Procedures ManualAccounting and Financial Policies and Procedures ManualApproved and Published:February 2019Table of ContentsIntroduction . 5General Policies. 5Organizational Structure . 5The Role of the Board . 5Committee Structure . 6Finance Committee Responsibilities . 6Accounting Department Overview . 7Organization . 7Responsibilities . 8Business Conduct . 8Practice of Ethical Behavior . 8Conflicts of Interest . 9Compliance with Laws, Regulations, and Organization Policies . 9Disciplinary Action . 9Fraud Policy . 9Scope . 9Policy . 10Actions Constituting Fraud. 10Other Irregularities . 10Investigation Responsibilities. 10Confidentiality . 11COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualAuthority for Investigation of Suspected Fraud . 11Reporting Procedures . 11Security . 12Accounting Department. 12Access to Electronically Stored Accounting Data. 12Storage of Back-up Files . 12General Office Security . 12Technology and Electronic Communications . 12Purpose and Scope. 12Acceptable Use of Organization Property. 13Password Security . 13Confidentiality . 13Copyrighted Information . 13Installation of Software. 14Other Prohibited Uses. 14Disciplinary Action for Violations . 14Reporting of Suspected Violations . 14General Ledger and Chart of Accounts . 15Chart of Accounts Overview . 15Distribution of Chart of Accounts . 15Control of Chart of Accounts . 15Account Definitions . 15Classification of Equity . 17Changes to the Chart of Accounts . 17Fiscal Year of Organization. 17Journal Entries. 17Policies Associated with Revenues and Cash Receipts . 18Revenue . 18Donations Received . 18Billing/Invoicing Policies. 19Cash Receipts . 20COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualAccounts Receivable Management. 21Policies Associated with Expenditures and Disbursements . 22Purchasing Policies and Procedures. 22Political Intervention . 26Accounts Payable Management . 27Travel and Business Expense . 29Cash Disbursements (check writing) Policies . 30Payroll and Related Policies . 31Policies Pertaining to Specific Asset and Liability Accounts . 36Cash and Cash Management. 36Inventory . 37Fixed Asset Management. 37Accrued Liabilities . 39Notes Payable . 39Policies Associated with Financial and Tax Reporting . 40Financial Statements . 40Government Returns . 42Financial Management Policies . 43Budgeting . 43Annual Audits . 45Insurance . 47Record Retention . 48Functional Expense Allocations . 49Policies Pertaining to Federal Awards . 53Administration of Federal Awards . 53Charging of Costs to Federal Awards . 60Equal Opportunity and Nondiscrimination Statement . 62Addenda / Revisions . 62COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualIntroductionThe following accounting manual is intended to provide an overview of the accounting policies andprocedures applicable to the Central Oklahoma Workforce Investment Board, Inc., which shall bereferred to as “Central Oklahoma Workforce Innovation Board (COWIB)” or “the Organization”throughout this manual.The Central Oklahoma Workforce Investment Board/dba the Central Oklahoma Workforce InnovationBoard is incorporated in the state of Oklahoma. Central Oklahoma Workforce Innovation Board isexempt from Federal income taxes under IRS Section 501(c)(3) as a nonprofit corporation. CentralOklahoma Workforce Innovation Board’s mission is as follows:Improving lives in our communitiesby building a quality workforcethrough education and creating connectionsbetween Job Seekers and BusinessesThis manual shall document the financial operations of the Organization. Its primary purpose is toformalize accounting policies and selected procedures for the accounting staff and to document internalcontrols.The Board approved the contents of this manual as official policy of the Organization. All CentralOklahoma Workforce Innovation Board staff are bound by the policies herein, and any deviation fromestablished policy is prohibited. The CEO has the authority to change the policy as it may be required byfederal, state or local regulations or policies.General PoliciesOrganizational StructureThe Role of the BoardThe Central Oklahoma Workforce Innovation Board is governed by its Board of Directors, which isresponsible for the oversight of the Organization by:1.2.3.4.5.6.Planning for the futureEstablishing broad policiesIdentifying and proactively dealing with emerging issuesInterpreting the Organization’s mission to the publicContracting for the Chief Executive OfficerEstablishing and maintaining programs and systems designed to assure compliance with termsof contracts and grants5COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualThe Board is responsible for hiring and periodically evaluating the Organization’s Chief Executive Officer,who shall be responsible for the day-to-day oversight and management of Central Oklahoma WorkforceInnovation Board.Committee StructureThe Board shall form committees in order to assist the Board in fulfilling its responsibilities. Thesecommittees represent vehicles for parceling out the Board’s work to smaller groups, thereby removingthe responsibility for evaluating all of the details of particular issues from the full Board’s consideration.Ad hoc committees that are time and focus limited may be created from time to time to act on specificfunctions for the organization. Formal Committees of Central Oklahoma Workforce Innovation Boardconsist of the following:1.2.3.4.Executive CommitteeFinance CommitteeSystem Partners CommitteeYouth CouncilSpecific guidelines regarding the composition and election of the Board and committees are described inthe Organization’s by-laws. However, roles of committees with direct responsibilities for the financialaffairs of the Organization are further described in this manual. These committees shall be referred to inappropriate sections of this manual.Finance Committee ResponsibilitiesThe Finance Committee is responsible for direction and oversight regarding the overall financialmanagement of Central Oklahoma Workforce Innovation Board. Functions of the Finance Committeeinclude:Review program budgets and expenditures, review audit reports, and financial aspects ofprogram monitoring reports, making recommendations as needed.The Finance Committee is responsible for recommending the hiring of an independent CPA firm. TheController and Chief Executive Officer are responsible for directly communicating with the CPA firm tofulfill the requirement for an annual audit, as described in the Organization’s by-laws. The FinanceCommittee shall also review and approve the final audited financial statements, as well as anycommunications received from the auditor regarding internal controls, illegal acts, or fraud. The reviewof the Organization’s financial statements shall not be limited to the finance committee, but shallinvolve the entire Board.The Finance Committee’s role in the annual audit is more fully explained in the section of this manualcovering the annual audit.The Roles of the Chief Executive Officer and StaffThe Board hires the Chief Executive Officer, who reports directly to the Board. The Chief ExecutiveOfficer is responsible for the hiring and annual evaluation of all employees of the agency. The ChiefExecutive Officer may delegate this responsibility to any other employee as needed.6COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualChief Operations Officer (COO) and Program Managers’ ResponsibilitiesThe COO and Program Managers are responsible for the proper oversight of program expenditures ofgrant funds incident to their area of responsibility and in accordance with funding source guidelines andAgency fiscal policies. They are further responsible for the management of allocated funds; ensuringfunds stay within line items in their budget, and authorizing the proper funding source and category indischarging financial obligations to the Accounting Department. The development of program budgetsis the responsibility of the Chief Executive Officer with final approval by the Board and Board of ChiefElected Officials (BCEO). Programmatic records will be retained for a period of three years after theaudit and/or resolution of any audit related findings.Fiscal Management ResponsibilitiesThe Chief Executive Officer is responsible for establishing and administering procedures necessary tocomply with the Fiscal Policies of the Board and the various funding sources. Coordination shall existbetween the Chief Executive Officer, Controller, the BCEO and the Officers of the Board. Specificresponsibilities include the maintenance of financial records, payment of bills, payrolls and all standardaccounting methods. In addition, the processing of monthly financial statements and financialprojections for the Chief Executive Officer shall be accomplished by the Controller. Proceduresestablished are directed towards the accountability of all funds received and disbursed on behalf of theagency and its mission.It shall be the responsibility of the Controller to retain all financial records for a period of three yearsafter the audit and/or resolution of any audit related findings.Employees’ ResponsibilitiesAll employees of the agency are responsible for the timely and accurate completion of fiscal documentsand forms. These should be completed in an efficient, cost effective manner ensuring that public fundsare properly expended toward achievement of the mission of the agency.Accounting Department OverviewOrganizationThe accounting department consists of two (2) staff that manages and processes financial informationfor Central Oklahoma Workforce Innovation Board, the South Central Oklahoma WorkforceDevelopment Board and the Western Oklahoma Workforce Development Board. The positionscomprising the accounting department of Central Oklahoma Workforce Innovation Board. are asfollows: ControllerAccounting AssistantOther officers and employees of Central Oklahoma Workforce Innovation Board. who have financialresponsibilities, and the abbreviations of each position used throughout this manual, are as follows: Chief Executive Officer (CEO)Chief Operations Officer (COO)Executive Committee (EC)7COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures Manual Finance Committee (FC)ResponsibilitiesThe primary responsibilities of the accounting department consist of:1. General Ledger2. Cash and Innovation Management3. Grants and Contracts Administration4. Accounts Receivable and Billing5. Accounts Payable6. Financial Statement Processing7. External Reporting of Financial Information8. Reconciliation of Sub-Ledgers9. Leases10. Compliance with Government Reporting Requirements11. Budgeting12. Asset Management13. Purchasing14. Cash Receipts15. Cash Disbursements16. Payroll and Benefits17. Bank Reconciliation18. Annual Audit19. InsuranceBusiness ConductPractice of Ethical BehaviorUnethical actions, or the appearance of unethical actions, are unacceptable under any conditions. Thepolicies and reputation of Central Oklahoma Workforce Innovation Board depend to a very large extenton the following considerations.Each employee must apply his/her own sense of personal ethics, which should extend beyondcompliance with applicable laws and regulations in business situations, to govern behavior where noexisting regulation provides a guideline. It is each employee's responsibility to apply common sense inbusiness decisions where specific rules do not provide all the answers. (see employees’ code of conduct)8COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures ManualChief Executive Officer is responsible for the ethical business behavior of his/her subordinates and mustweigh carefully all courses of action suggested in ethical, as well as economic terms, and base his/herfinal decisions on the guidelines provided by this policy, as well as his/her personal sense of right andwrong.Conflicts of InterestIn addition, no employee, officer, agent or member of the board of Central Oklahoma WorkforceInnovation Board shall participate in the selection, award, or administration of a contract involvingCentral Oklahoma Workforce Innovation Board if a real or apparent conflict of interest would beinvolved. Such a conflict would arise when the employee, officer, or agent, or any member of his/herimmediate family, his or her partner, or an Organization that employs or is about to employ any of theparties indicated herein, has a financial or other interest in the firm selected. All employees and BoardMembers are required to sign a conflict of interest form.Compliance with Laws, Regulations, and Organization PoliciesThe Central Oklahoma Workforce Innovation Board does not tolerate the willful violation orcircumvention of any Federal, state, local, or foreign law by an employee during the course of thatperson's employment; nor does the Organization tolerate the disregard or circumvention of CentralOklahoma Workforce Innovation Board policy or engagement in unscrupulous dealings. Employeesshould not attempt to accomplish by indirect means, through agents, or intermediaries, that which isdirectly forbidden.Implementation of the provisions of this policy is one of the standards by which the performance of alllevels of employees will be measured.Disciplinary ActionFailure to comply with the standards contained in this policy or any other policy will result in disciplinaryaction that may include termination, referral for criminal prosecution, and reimbursement to theOrganization or to the government, for any loss or damage resulting from the violation. As with allmatters involving disciplinary action, principles of fairness will apply. Any employee charged with aviolation of this policy will be afforded an opportunity to explain her/his actions before disciplinaryaction is taken.Disciplinary action will be taken:1.Against any employee who authorizes or participates directly in actions that are a violation of thispolicy.2. Against any employee who has deliberately failed to report a violation or deliberately withheldrelevant and material information concerning a violation of this policy.3. Against any employee who attempts to retaliate, directly or indirectly, or encourages others todo so, against any employee who reports a violation of this policy.Fraud PolicyScopeThis policy applies to any fraud or suspected fraud involving employees, officers or directors, as well asmembers, vendors, consultants, contractors, funding sources and/or any other parties with a business9COWIB is an Equal Opportunity Employer/ Program. Auxiliary aids and services are available upon request to individualswith disabilities. This was financed in whole or in part by fund from the US Dept. of Labor as administered by theOklahoma Office of Workforce Development.
Accounting and Financial Policies Procedures Manualrelationship with Central Oklahoma Workforce Innovation Board. Any investigative activity required willbe conducted without regard to the suspected wrongdoer’s length of service, position/title, orrelationship with Central Oklahoma Workforce Innovation Board.PolicyManagement is responsible for the detection and prevention of fraud, misappropriations, and otherirregularities. Fraud is defined as the intentional, false representation or concealment of a material fact,or the intentional perversion of truth in order to induce another to part with something of value. Eachmember of the management team will be familiar with the types of improprieties that might occurwithin his or her area of responsibility, and be alert for any indication of irregularity.Any fraud that is detected or suspected must be reported immediately to the Chief Executive Officer,Controller or, alternatively, to the Chair of the Central Oklahoma Workforce Innovation Board, whocoordinates all investigations.Actions Constituting FraudThe terms fraud, defalcation, misappropriation, and other fiscal irregularities refer to, but are notlimited to:1.Any dishonest or fraudulent act2.Forgery or alteration of any document or account belonging to Central Oklahoma WorkforceInnovation Board3.Forgery or alteration of a check, bank draft, or any other financial document4.Misappropriation of funds, securities, supplies, equipment, or other assets of Central OklahomaWorkforce Innovation Board5.Impropriety in the handling or reporting of money or financial transactions6.Disclosing confidential and proprietary information to outside parties7.Accepting or seeking anything of material value from contractors, vendors, or persons providinggoods or services to Central Oklahoma Workforce Innovation Board. Exception: gifts less than amaterial value.8.Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment9.Any similar or related irregularityOther IrregularitiesIrregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by thedepartmental management and the Chief Executive Office
formalize accounting policies and selected procedures for the accounting staff and to document internal controls. The Board approved the contents of this manual as official policy of the Organization. All Central Oklahoma Workforce Innovation Board staff are bound by the policies herein, and any deviation from established policy is prohibited.
