2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-003 – Special Tests and Provisions – Wage Rate Requirements
Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance.
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.42C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires that all laborers and mechanics employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations, which include a requirement to obtain weekly certified payrolls from contractors.
Condition. The contracts tested that were subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls.
Cause. The District does not have the proper internal controls in place to ensure that all contracts awarded have complied with federal requirements or that the prevailing wage was paid by all contractors.
Effect. The District did not follow federal requirements to include the prevailing wage rate provision in its contract or obtain the required certified payrolls.
Questioned Costs. The total charges included in our testing that were not supported by allowable documentation amounted to $162,171.
Recommendation. We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained.
View of Responsible Officials. District officials will ensure that construction contracts contain these requirements during the bid process.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-004 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial noncompliance
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Special Education Cluster (IDEA) (84.027 and 84.173); Passed through the Wayne County Regional Educational Service Agency; All project numbers.
Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431).
Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation.
Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance.
Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year.
View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024
2023-003 – Special Tests and Provisions – Wage Rate Requirements
Finding Type. Material Noncompliance; Material Weakness in Internal Controls over Compliance.
Federal program(s)
U.S. Department of Education -
COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.42C, and 84.425U); Passed through the Michigan Department of Education; All project numbers.
Criteria. The Uniform Guidance requires that all laborers and mechanics employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations, which include a requirement to obtain weekly certified payrolls from contractors.
Condition. The contracts tested that were subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls.
Cause. The District does not have the proper internal controls in place to ensure that all contracts awarded have complied with federal requirements or that the prevailing wage was paid by all contractors.
Effect. The District did not follow federal requirements to include the prevailing wage rate provision in its contract or obtain the required certified payrolls.
Questioned Costs. The total charges included in our testing that were not supported by allowable documentation amounted to $162,171.
Recommendation. We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained.
View of Responsible Officials. District officials will ensure that construction contracts contain these requirements during the bid process.
Responsible Official. Chief Financial Officer
Estimated Completion Date. June 30, 2024