Audit 298412

Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants Federal Award Identification Number and Year - N/A Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity Finding Type - Significant deficiency Repeat Finding - No Criteria - The College should have a subrecipient monitoring policy and defined procedures to follow when identifying and assessing subrecipients in accordance with 2 CFR section 200.332. Condition - The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Questioned Costs - N/A Context - There was one subrecipient for this grant. The College was required to find a subrecipient and selected a similar organization that they collaborate with on other projects. The selected subrecipient meets with the College monthly and provides and submit quarterly reimbursement forms and performance data. This is also the College's first subrecipient agreement. Cause and Effect - The College did not have a system or process in place to select a subrecipient using a risk analysis process. As a result, the subrecipient chosen may not have been eligible or at risk of providing timely or accurate performance and financial data. Recommendation - We recommend the College develop a subrecipient policy with defined procedures in alignment with Uniform Guidance in the efect they have subrecipients in the future for this and other grants. Views of Responsible Officals and Corrective Action Plan - The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management.

Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants Federal Award Identification Number and Year - N/A Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity Finding Type - Significant deficiency Repeat Finding - N/A Criteria - In accordance with the grant agreement, the College was responsible for determining eligibility and maintaining certain documentation to support the eligibility of the participants in the program. Condition - The College provided funds to two individuals for transportation in advance of being approved for participation in the program. Questioned Costs - $125 Identification of How Questioned Costs Were Computed - The questioned costs were determined by totaling all the assistance received by the two applicants in advance of eligibility determination. Context - For 2 out of 27 students tested, there was not enough documentation or approval of eligibility to participate prior to funds being provided for transportation assistance. Cause and Effect - The requirements of the application process were not followed resulting in applicants receiving services of the grant prior to approved participation which could result in unallowable costs charged to the grant. Recommendation - We recommend additional controls be put in place to determine that all documentation is maintained to support that an applicant is eligible to participate in the program. Views of Responsible Officials and Planned Corrective Actions - The College has returned the questioned costs by transferring the expenditures out of the grant funds and reducing the next drawdown for the grant. The College will immediately suspend the practice of providing grant funds to individuals prior to their approval for participation in program. Moving forward, the College will require the Program Director to approve all applicants for eligibility prior to any training or support activities beginning. This will include a review of the application materials, eligibility documents, and any other required materials. Participants who do not meet the eligibility requirements will receive written notice of the reason for denial and will not be admitted to any programming or receive any supportive services. The College will also look to have staff members involved in grant administration receive targeted training and education on the revised grant disbursement procedures as well as general grant administration training.

Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants Federal Award Identification Number and Year - N/A Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity Finding Type - Significant deficiency Repeat Finding - No Criteria - The College should have a subrecipient monitoring policy and defined procedures to follow when identifying and assessing subrecipients in accordance with 2 CFR section 200.332. Condition - The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Questioned Costs - N/A Context - There was one subrecipient for this grant. The College was required to find a subrecipient and selected a similar organization that they collaborate with on other projects. The selected subrecipient meets with the College monthly and provides and submit quarterly reimbursement forms and performance data. This is also the College's first subrecipient agreement. Cause and Effect - The College did not have a system or process in place to select a subrecipient using a risk analysis process. As a result, the subrecipient chosen may not have been eligible or at risk of providing timely or accurate performance and financial data. Recommendation - We recommend the College develop a subrecipient policy with defined procedures in alignment with Uniform Guidance in the efect they have subrecipients in the future for this and other grants. Views of Responsible Officals and Corrective Action Plan - The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management.

Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants Federal Award Identification Number and Year - N/A Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity Finding Type - Significant deficiency Repeat Finding - N/A Criteria - In accordance with the grant agreement, the College was responsible for determining eligibility and maintaining certain documentation to support the eligibility of the participants in the program. Condition - The College provided funds to two individuals for transportation in advance of being approved for participation in the program. Questioned Costs - $125 Identification of How Questioned Costs Were Computed - The questioned costs were determined by totaling all the assistance received by the two applicants in advance of eligibility determination. Context - For 2 out of 27 students tested, there was not enough documentation or approval of eligibility to participate prior to funds being provided for transportation assistance. Cause and Effect - The requirements of the application process were not followed resulting in applicants receiving services of the grant prior to approved participation which could result in unallowable costs charged to the grant. Recommendation - We recommend additional controls be put in place to determine that all documentation is maintained to support that an applicant is eligible to participate in the program. Views of Responsible Officials and Planned Corrective Actions - The College has returned the questioned costs by transferring the expenditures out of the grant funds and reducing the next drawdown for the grant. The College will immediately suspend the practice of providing grant funds to individuals prior to their approval for participation in program. Moving forward, the College will require the Program Director to approve all applicants for eligibility prior to any training or support activities beginning. This will include a review of the application materials, eligibility documents, and any other required materials. Participants who do not meet the eligibility requirements will receive written notice of the reason for denial and will not be admitted to any programming or receive any supportive services. The College will also look to have staff members involved in grant administration receive targeted training and education on the revised grant disbursement procedures as well as general grant administration training.