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  2. Employment & Training
  3. Partners
  4. WIOA Title I-A & I-B
  5. Policy & Procedure Manual
  6. 4.4 Cash Management and Invoicing Standards

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4.4 Cash Management and Invoicing Standards

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4.4.1 Cash Management and Invoicing Standards

Effective Date: October 1, 2025

Background

There is a strong emphasis in Uniform Guidance on having a cash management system in place to accurately track the receipt, disbursement and recording of funds between the awarding agency and grant recipient.1 This policy specifies the minimum requirements for cash management and provides guidelines for the reimbursement of Workforce Innovation and Opportunity Act (WIOA) funds from the Department of Workforce Development (DWD).

Cash Management

The local Workforce Development Board (WDB) must have a written cash management policy and/or procedures that minimally address the following:

  1. Adequate internal controls2 to safeguard cash and cash equivalent assets.3
    1. Cash equivalent assets include, but are not limited to:
      1. ATM PINs & PINs to checking accounts
      2. Passwords to sensitive accounts
      3. Credit Cards and/or Gas Cards
      4. Debit Cards
      5. Purchase Cards
      6. Blank check stock
      7. Check-signing machines
      8. Bus tokens and passes
      9. Gift Cards
    2. For more information regarding internal controls, please visit: https://www.coso.org/guidance-on-ic
  2. Recovering improper payments. The costs incurred by a non-Federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate.4
    1. Improper payments5 include but are not limited to:
      1. Over-payments to subawards and contractors
      2. Disallowed costs
      3. Participant payments erroneously awarded
      4. Uncollected tuition refunds
      5. Double payments
      6. Payments paid at the wrong rate
      7. Unauthorized charges on fees and penalties paid in error
      8. Overpayments on blanket P.O.s
  3. Cash Forecasting Method. Mechanism or tool used by the local WDB to determine the amount of cash to draw.
  4. Payment of non-sufficient funds, overdraft fees, and other penalties which cannot be paid using Federal Funds.6
  5. Reconciliation. Reconciliation must be performed between the cash drawdowns and the expenditures on an individual grant basis, monthly. Local WDBs must separately account for receipt, obligation, and expenditure of funds by award or fund source.
  6. Authorized individuals and separation of duties. Sufficient internal controls must be in place to ensure proper segregation of duties for the following functions: recording, custodian, authorizing, and reconciliation of funds.7
  7. Accounting Records. Records relevant to drawdowns and supporting documentation must be retained by the WDB or the WDB's fiscal agent.8

Invoicing Standards

This Section Outlines Invoicing Requirements for All Contracts Executed Prior To Program Year 2025 (PY25)

Cash requests are to be made on a per Purchase Order (PO) number basis. An invoice may reference more than one PO number if there is a need to correct a prior invoice payment for an open PO. The total invoice amount must be equal to or greater than $0.00. Emphasis must be placed on minimizing the time between the transfer of funds from DWD-DET and the disbursement of funds to pay allowable costs.9

To request cash, a supplier must complete the Supplier Request for Payment Invoice Form and supply documentation to substantiate their cash drawdown request. This documentation must reconcile with the total amount of cash being requested, and may include, but is not limited to the following:

  1. Accounting records such as general ledger, trial balance, and/or payroll ledger.
  2. Accrued expenditure documentation detailing the following:
    1. Wages and salaries earned but not paid
    2. Invoices received but not paid
    3. Subrecipient accrued expenditure reports received but not paid
    4. Payments earned on an OJT contract as of the end of a month but not yet due or paid to the employer)

All documentation must be emailed to DWDDETInvoicing@dwd.wisconsin.gov.

The following may result in delayed payment:

  1. Incomplete and/or inaccurate cash requests, including, but not limited to, requests lacking sufficient documentation and/or requests where the documentation provided does not reconcile with the total amount of cash requested.
  2. Late submissions of required Financial Status Reports (FSRs) for two or more consecutive months.
  3. Conditions of persistent non-compliance.

Unless there is an issue, reimbursements are processed within 5 business days.

Invoicing Standards COMET Invoicing 2025

This Section Outlines Invoicing Requirements for All WIOA Contracts Executed from Program Year 2025 (PY25)

Cash requests must be submitted on a per-contract-number basis. An invoice may reference more than one contract number only when correcting a prior invoice payment related to an open contract (Financial Adjustment). Cash requests amount must be equal to or greater than $0.00.

Emphasis must be placed on minimizing the time between the receipt of funds from DWD-DET and the disbursement of those funds to cover allowable costs.9

Two types of invoices may be created and submitted through COMET Invoicing:

  1. Invoice Types and Submission Requirements
    Invoices may be created and submitted in COMET Invoicing as follows:
    1. Standard Invoice
      • Per contract may allow submission of one or more invoices for same period.
      • Supporting documentation must be attached to substantiate all amounts requested.
    2. Financial Adjustment
      • Used exclusively to correct a prior invoice payment for an open contract.
      • May reference up to two contract numbers if correcting across contracts.
      • The total invoice amount must be equal to or greater than $0.00.
      • All supporting documentation related to the adjustment must be provided.
  2. Supporting Documentation Submission
    Suppliers requesting cash payments must use the following Link: https://dwd.wisconsin.gov/detapps and provide documentation to support the cash drawdown request.
  3. Supporting Documentation Requirements

All documentation must reconcile with the total amount requested and may include, but is not limited to:

  • Accounting records such as the general ledger, trial balance, payroll ledger, or financial statements.
  • Accrued expenditure documentation, including:
    • Wages and salaries earned but not yet paid
    • Invoices received but not yet paid
    • Subrecipient accrued expenditure reports received but not yet paid
    • Payments earned under an OJT (On-the-Job Training) contract as of month-end but not yet due or paid to the employer

Documentation must be attached to each invoice submitted through COMET Invoicing. Invoices without the required supporting documentation will not be processed for payment.

Common Reasons for Delayed Payment

Delays in processing may occur due to:

  1. Incomplete or inaccurate requests, including insufficient documentation or documentation that does not reconcile with the requested amount
  2. Failure to submit required Financial Status Reports (FSRs) for two or more consecutive months
  3. Persistent non-compliance with invoicing requirements

Processing Time

Unless there is an issue, reimbursements are processed within 5 business days.

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