Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year E2022241300; E20223664-00 Pass through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.501(g), Federal award compliance requirements normally do not pass through to the contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs. Context - During eligibility testing, we noted 16 out of 40 eligibility samples whereby employers of the contractor performed both the intake and the certification and review function, with no further review by a County representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with Unifor m Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a County representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor.
Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year E2022241300; E20223664-00 Pass through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.501(g), Federal award compliance requirements normally do not pass through to the contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs. Context - During eligibility testing, we noted 16 out of 40 eligibility samples whereby employers of the contractor performed both the intake and the certification and review function, with no further review by a County representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with Unifor m Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a County representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 21.023, Department of the Treasury, COVID-19 Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA2-0476 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per the 2022 Compliance Supplement for ALN 21.023, financial assistance for eligible households may include payment of rent, rent arrears, utilities and home energy costs, utilities and home energy costs arrears, and any other expenses related to housing. Condition - The County did not have adequate controls in place to ensure that payments to beneficiaries were calculated correctly. Questioned Costs - $21,529 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance cases selected for testing, 6 samples were not calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program and paid to the beneficiary. In three of the six instances, the County did not consider partial rent payments made by the beneficiaries. In the other instances, the County did not have adequate documentation to support an amount included in the calculation of benefits. Cause and Effect - While the County has procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the County disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend that the County review its controls specific to the calculation of benefits to ensure that inputs used in the calculation are supported by adequate documentation. We also recommend that the County assess whether the reviewer should be required to recalculate the benefit payment. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing of consultant administered activity for accuracy by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 93.224, Department of Health and Human Services, Health Center Cluster, including COVID-19 Federal Award Identification Number and Year - H80CS24135 08 03; 1 H8FCS41413-01-00; Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay as follows : a. Sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the FPG, or the health center applies only a nominal charge; b. A full discount is applied to fees for the health center services provided to individuals and families with annual incomes at or below 100 percent of the FPG, or the health center applies only a nominal charge; c. Fees for health center services are discounted based on gradations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FPG; and d.No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the FPG. Condition - The County has a sliding fee discount policy that is based on income and family size and schedule in place; however, it was not followed for all patients during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For 4 of a sample of 40 patients during the year, the sliding fee discount applied was not in accordance with the County's approved sliding fee discount schedule in place. Cause and Effect - Inaccurate date input by intake staff was the identified cause for 3 of the errors and an incorrect calculation by the electronic health record system that was not detected was the cause for 1 error. The result was the patients were not charged the correct amount for services based on the sliding fee discount which they qualified for based on supporting documentation provided by the patient. Recommendation - We recommend a process be implemented to ensure the sliding fee discount provided to the patients is reviewed within the electronic health record system for inconsistency with the patient provided support for the discount. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing accuracy of intake data and application of sliding fee calculations performed by co-applicant employees by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 93.224, Department of Health and Human Services, Health Center Cluster, including COVID-19 Federal Award Identification Number and Year - H80CS24135 08 03; 1 H8FCS41413-01-00; Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay as follows : a. Sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the FPG, or the health center applies only a nominal charge; b. A full discount is applied to fees for the health center services provided to individuals and families with annual incomes at or below 100 percent of the FPG, or the health center applies only a nominal charge; c. Fees for health center services are discounted based on gradations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FPG; and d.No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the FPG. Condition - The County has a sliding fee discount policy that is based on income and family size and schedule in place; however, it was not followed for all patients during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For 4 of a sample of 40 patients during the year, the sliding fee discount applied was not in accordance with the County's approved sliding fee discount schedule in place. Cause and Effect - Inaccurate date input by intake staff was the identified cause for 3 of the errors and an incorrect calculation by the electronic health record system that was not detected was the cause for 1 error. The result was the patients were not charged the correct amount for services based on the sliding fee discount which they qualified for based on supporting documentation provided by the patient. Recommendation - We recommend a process be implemented to ensure the sliding fee discount provided to the patients is reviewed within the electronic health record system for inconsistency with the patient provided support for the discount. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing accuracy of intake data and application of sliding fee calculations performed by co-applicant employees by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year E2022241300; E20223664-00 Pass through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.501(g), Federal award compliance requirements normally do not pass through to the contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs. Context - During eligibility testing, we noted 16 out of 40 eligibility samples whereby employers of the contractor performed both the intake and the certification and review function, with no further review by a County representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with Unifor m Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a County representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor.
Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year E2022241300; E20223664-00 Pass through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.501(g), Federal award compliance requirements normally do not pass through to the contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs. Context - During eligibility testing, we noted 16 out of 40 eligibility samples whereby employers of the contractor performed both the intake and the certification and review function, with no further review by a County representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with Unifor m Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a County representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 21.023, Department of the Treasury, COVID-19 Emergency Rental Assistance Program Federal Award Identification Number and Year - ERA2-0476 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per the 2022 Compliance Supplement for ALN 21.023, financial assistance for eligible households may include payment of rent, rent arrears, utilities and home energy costs, utilities and home energy costs arrears, and any other expenses related to housing. Condition - The County did not have adequate controls in place to ensure that payments to beneficiaries were calculated correctly. Questioned Costs - $21,529 Identification of How Questioned Costs Were Computed - Questioned costs were computed based on the difference between the rental assistance payment disbursed and the rental assistance payment calculated in accordance with the U.S. Treasury guidance. Context - Out of a sample of 60 assistance cases selected for testing, 6 samples were not calculated in accordance with the U.S. Treasury guidance. The inaccurate calculation caused an overpayment in rental assistance charged to the program and paid to the beneficiary. In three of the six instances, the County did not consider partial rent payments made by the beneficiaries. In the other instances, the County did not have adequate documentation to support an amount included in the calculation of benefits. Cause and Effect - While the County has procedures in place to review the rental assistance calculations, management's review did not prevent an inaccurate assistance payment. As a result, the County disbursed an amount that was not calculated in accordance with the U.S. Treasury guidance. Recommendation - We recommend that the County review its controls specific to the calculation of benefits to ensure that inputs used in the calculation are supported by adequate documentation. We also recommend that the County assess whether the reviewer should be required to recalculate the benefit payment. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing of consultant administered activity for accuracy by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 93.224, Department of Health and Human Services, Health Center Cluster, including COVID-19 Federal Award Identification Number and Year - H80CS24135 08 03; 1 H8FCS41413-01-00; Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay as follows : a. Sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the FPG, or the health center applies only a nominal charge; b. A full discount is applied to fees for the health center services provided to individuals and families with annual incomes at or below 100 percent of the FPG, or the health center applies only a nominal charge; c. Fees for health center services are discounted based on gradations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FPG; and d.No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the FPG. Condition - The County has a sliding fee discount policy that is based on income and family size and schedule in place; however, it was not followed for all patients during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For 4 of a sample of 40 patients during the year, the sliding fee discount applied was not in accordance with the County's approved sliding fee discount schedule in place. Cause and Effect - Inaccurate date input by intake staff was the identified cause for 3 of the errors and an incorrect calculation by the electronic health record system that was not detected was the cause for 1 error. The result was the patients were not charged the correct amount for services based on the sliding fee discount which they qualified for based on supporting documentation provided by the patient. Recommendation - We recommend a process be implemented to ensure the sliding fee discount provided to the patients is reviewed within the electronic health record system for inconsistency with the patient provided support for the discount. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing accuracy of intake data and application of sliding fee calculations performed by co-applicant employees by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 93.224, Department of Health and Human Services, Health Center Cluster, including COVID-19 Federal Award Identification Number and Year - H80CS24135 08 03; 1 H8FCS41413-01-00; Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient's ability to pay as follows : a. Sliding fee discounts are applied to fees for health center services provided to all individuals and families with annual incomes at or below 200 percent of the FPG, or the health center applies only a nominal charge; b. A full discount is applied to fees for the health center services provided to individuals and families with annual incomes at or below 100 percent of the FPG, or the health center applies only a nominal charge; c. Fees for health center services are discounted based on gradations in family size and income for individuals and families with incomes above 100 and at or below 200 percent of the FPG; and d.No sliding fee discount is applied to fees for health center services provided to individuals and families with annual incomes above 200 percent of the FPG. Condition - The County has a sliding fee discount policy that is based on income and family size and schedule in place; however, it was not followed for all patients during the year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For 4 of a sample of 40 patients during the year, the sliding fee discount applied was not in accordance with the County's approved sliding fee discount schedule in place. Cause and Effect - Inaccurate date input by intake staff was the identified cause for 3 of the errors and an incorrect calculation by the electronic health record system that was not detected was the cause for 1 error. The result was the patients were not charged the correct amount for services based on the sliding fee discount which they qualified for based on supporting documentation provided by the patient. Recommendation - We recommend a process be implemented to ensure the sliding fee discount provided to the patients is reviewed within the electronic health record system for inconsistency with the patient provided support for the discount. Views of Responsible Officials and Planned Corrective Actions - Management will implement and follow a process of reviewing accuracy of intake data and application of sliding fee calculations performed by co-applicant employees by internal County representative.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.
Assistance Listing Number, Federal Agency, and Program Name - 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME) 93.563 ? Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) Federal Award Identification Number and Year - CDBG ? B-20-UC-26-0003 and B-21-UC-26-0003 HOME ? M-21-DC260213 CSE ? CSCOM-17-82003 Pass through Entity - HOME and CDBG ? N/A, direct funded CSE - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct Federal awards, to submit annually to its Federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County's self insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County?s process for allocating self insurance costs across the various departments as well as the annual chargeback plan, we noted the County did not submit its plan for self insurance costs nor its annual action plan to its Federal cognizant agency for approval. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID funding, the County received direct funded awards in excess of $100 million, therefore becoming a "major local government." Prior to 2020 the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government requiring different documentation and submission requirements for the self insurance cost allocation process and annual chargeback plan. As a result, these plans were not submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable Appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a Federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200.