Audit 309459

FY End
2023-12-31
Total Expended
$2.04M
Findings
4
Programs
12
Organization: Leelanau County, Michigan (MI)
Year: 2023 Accepted: 2024-06-21

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
401356 2023-004 Significant Deficiency - ABCI
401357 2023-005 Significant Deficiency - I
977798 2023-004 Significant Deficiency - ABCI
977799 2023-005 Significant Deficiency - I

Contacts

Name Title Type
NGV7GJXHMUZ8 Catherine Hartesvelt Auditee
2312569824 Paul Matz, Cpa, Cgfm Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Leelanau County, Michigan (the “County”) under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the County, it is not intended to and does not present the financial position, changes in net position or cash flows of the County. The County’s reporting entity is defined in Note 1 of the County’s financial statements. The County’s financial statements include the operations of the Leelanau County Road Commission a discretely presented component unit, which received federal awards that are not included in the Schedule for the year ended December 31, 2023, as this entity was separately audited. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting, which is described in Note 1 to the County's financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance or other applicable guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: Y Rate Explanation: For purposes of charging indirect costs to federal awards, the County has not elected to use the de minimis cost rate as permitted by §200.414 of the Uniform Guidance.

Finding Details

2023-004 – Written Policies and Procedures Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027. 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 various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the County has processes in place to cover these areas, there are no formal written policies covering payments, procurement, and allowability of costs that address all of the areas required by the Uniform Guidance. 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 County did not fully comply with the Uniform Guidance. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the County draft the required policies as soon as practical, but no later then the end of fiscal year 2024. View of Responsible Officials. Management agrees with the finding and has prepared a corrective action plan.
2023-005 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the County. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The County did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the County. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the County was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the County verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. View of Responsible Officials. Management agrees with the finding and has prepared a corrective action plan.
2023-004 – Written Policies and Procedures Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027. 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 various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the County has processes in place to cover these areas, there are no formal written policies covering payments, procurement, and allowability of costs that address all of the areas required by the Uniform Guidance. 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 County did not fully comply with the Uniform Guidance. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the County draft the required policies as soon as practical, but no later then the end of fiscal year 2024. View of Responsible Officials. Management agrees with the finding and has prepared a corrective action plan.
2023-005 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the County. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The County did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the County. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the County was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the County verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. View of Responsible Officials. Management agrees with the finding and has prepared a corrective action plan.