U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirements: All twelve areas of compliance
Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to establish and maintain effective internal control over the federal award that provides a reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The required internal control procedures should address the five components of internal control for each of the applicable twelve areas of compliance for each federal award maintained by the non-federal entity.
Questioned Costs: None.
Condition: The Organization does not have written internal control procedure memos for any of its federal programs.
Context: During our audit of the Crime Victim Assistance program, it was noted that the Organization does not have written internal control procedure memos as mandated by the Uniform Guidance that cover the required five components of internal control for each area of compliance. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: Essential internal control steps may be lacking for federal programs without the adoption of written internal control procedure memos, potentially resulting in issues of noncompliance.
Cause: The Organization was unaware of the requirement to establish and maintain written procedure memos for each of its federal program.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish and maintain written internal control procedures that cover the required five components of internal control for each area of compliance for each of its federal programs. The Organization should educate all employees working with federal programs of the Organization’s procedures and monitor compliance with them.
Views of Responsible Officials: The Organization agrees with this finding.
U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirement: (B.) Allowable Costs/Cost Principles, (C.) Cash Management, (L.) Reporting
Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to establish and maintain effective internal control over the federal award that provides a reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination.
Questioned Costs: None.
Condition: During our detailed testing of the areas of indirect costs, cash management, and reporting for the Crime Victim Assistance program, we noted that the indirect cost calculations, requests for funds, and reports were missing documented approval by an appropriate individual with adequate skills, knowledge, and experience.
Context: Of the three months selected for testing indirect cost calculations and requests for funds, none of the calculations or requests were reviewed and approved by an appropriate individual. Additionally, of the three monthly activity reports and the two quarterly reports tested, none of the reports were reviewed and approved by an appropriate individual. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: Failure to properly prepare and review indirect cost calculations and requests for funds could allow funds to be over requested and potentially overstate federal revenue, resulting in excess funds paid to the Organization. Similarly, there could also be missed opportunities for reimbursement. In addition, failure to properly review reports before they are submitted could result in inaccurate information being transmitted, resulting in a compliance finding.
Cause: The Organization was unaware of the requirement to have a documented review and approval over the areas of indirect costs, cash management, and reporting.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish procedures to require the documented review and approval of all indirect cost calculations, cash management requests for funds, and reports by an individual with adequate skills, knowledge, and experience prior to submission.
Views of Responsible Officials: The Organization agrees with this finding.
U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirements: (F.) Equipment
Criteria: Section 200.313(d) of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to (1) maintain property records that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds the title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property, (2) perform a physical inventory of the property and reconcile the results with the property records at least once every two years, (3) develop a control system to ensure adequate safeguards to prevent loss, damage, or theft of the property with any suspected loss, damage or theft investigated.
Questioned Costs: None.
Condition: The listing maintained by the Organization for assets acquired with federal funds was lacking certain required elements. In addition, a physical inventory was not performed and documented, and the results were not reconciled with the property records as required.
Context: The Organization maintains a listing of fixed assets that it owns. We noted that the listing properly contained descriptions of the property, identification numbers, locations, federal funding sources, acquisition dates, and cost of the property. However, the fixed asset listing was lacking percentages of federal participation in the costs of fixed assets acquired under federal awards and the conditions of the property as required. In addition, the Organization did not perform and document a physical inventory of the property and reconcile the results with the property records at least once every two years as required. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: A control system has not been fully implemented to safeguard the fixed assets to prevent loss, damage or theft and promptly investigate missing items. Failure to maintain adequate detailed fixed asset records with all the required elements, failure to perform a physical inventory of the property, and failure to reconcile the inventory results with the property records could lead to the loss or misappropriation of these assets.
Cause: The Organization was unaware of the requirements to maintain adequate detailed fixed asset records with specified elements, perform a physical inventory of the property and reconcile the results with the property records at least once every two years. As a result, the Organization did not have proper policies and procedures in place to ensure that these required steps were completed.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish procedures to require the maintenance of detailed fixed asset records that include all specified elements. In addition, the Organization should perform a physical inventory of the property and reconcile the results with fixed asset records at least once every two years to help prevent loss, damage, or theft of the property.
Views of Responsible Officials: The Organization agrees with this finding.
U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirements: All twelve areas of compliance
Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to establish and maintain effective internal control over the federal award that provides a reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The required internal control procedures should address the five components of internal control for each of the applicable twelve areas of compliance for each federal award maintained by the non-federal entity.
Questioned Costs: None.
Condition: The Organization does not have written internal control procedure memos for any of its federal programs.
Context: During our audit of the Crime Victim Assistance program, it was noted that the Organization does not have written internal control procedure memos as mandated by the Uniform Guidance that cover the required five components of internal control for each area of compliance. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: Essential internal control steps may be lacking for federal programs without the adoption of written internal control procedure memos, potentially resulting in issues of noncompliance.
Cause: The Organization was unaware of the requirement to establish and maintain written procedure memos for each of its federal program.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish and maintain written internal control procedures that cover the required five components of internal control for each area of compliance for each of its federal programs. The Organization should educate all employees working with federal programs of the Organization’s procedures and monitor compliance with them.
Views of Responsible Officials: The Organization agrees with this finding.
U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirement: (B.) Allowable Costs/Cost Principles, (C.) Cash Management, (L.) Reporting
Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to establish and maintain effective internal control over the federal award that provides a reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination.
Questioned Costs: None.
Condition: During our detailed testing of the areas of indirect costs, cash management, and reporting for the Crime Victim Assistance program, we noted that the indirect cost calculations, requests for funds, and reports were missing documented approval by an appropriate individual with adequate skills, knowledge, and experience.
Context: Of the three months selected for testing indirect cost calculations and requests for funds, none of the calculations or requests were reviewed and approved by an appropriate individual. Additionally, of the three monthly activity reports and the two quarterly reports tested, none of the reports were reviewed and approved by an appropriate individual. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: Failure to properly prepare and review indirect cost calculations and requests for funds could allow funds to be over requested and potentially overstate federal revenue, resulting in excess funds paid to the Organization. Similarly, there could also be missed opportunities for reimbursement. In addition, failure to properly review reports before they are submitted could result in inaccurate information being transmitted, resulting in a compliance finding.
Cause: The Organization was unaware of the requirement to have a documented review and approval over the areas of indirect costs, cash management, and reporting.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish procedures to require the documented review and approval of all indirect cost calculations, cash management requests for funds, and reports by an individual with adequate skills, knowledge, and experience prior to submission.
Views of Responsible Officials: The Organization agrees with this finding.
U.S. Department of Justice
Pass-through Entity: Michigan Department of Health and Human Services
Assistance Listing Number: 16.575
Award Numbers: E20232575-00, E20233017-00, E20233431-00
Award Year End: September 30, 2023
Specific Requirements: (F.) Equipment
Criteria: Section 200.313(d) of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-federal entity to (1) maintain property records that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds the title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property, (2) perform a physical inventory of the property and reconcile the results with the property records at least once every two years, (3) develop a control system to ensure adequate safeguards to prevent loss, damage, or theft of the property with any suspected loss, damage or theft investigated.
Questioned Costs: None.
Condition: The listing maintained by the Organization for assets acquired with federal funds was lacking certain required elements. In addition, a physical inventory was not performed and documented, and the results were not reconciled with the property records as required.
Context: The Organization maintains a listing of fixed assets that it owns. We noted that the listing properly contained descriptions of the property, identification numbers, locations, federal funding sources, acquisition dates, and cost of the property. However, the fixed asset listing was lacking percentages of federal participation in the costs of fixed assets acquired under federal awards and the conditions of the property as required. In addition, the Organization did not perform and document a physical inventory of the property and reconcile the results with the property records at least once every two years as required. The sample was not a statistically valid sample, and the matter appears to be a systemic condition.
Effect: A control system has not been fully implemented to safeguard the fixed assets to prevent loss, damage or theft and promptly investigate missing items. Failure to maintain adequate detailed fixed asset records with all the required elements, failure to perform a physical inventory of the property, and failure to reconcile the inventory results with the property records could lead to the loss or misappropriation of these assets.
Cause: The Organization was unaware of the requirements to maintain adequate detailed fixed asset records with specified elements, perform a physical inventory of the property and reconcile the results with the property records at least once every two years. As a result, the Organization did not have proper policies and procedures in place to ensure that these required steps were completed.
Repeat Finding: This is not a repeat finding.
Recommendation: The Organization should establish procedures to require the maintenance of detailed fixed asset records that include all specified elements. In addition, the Organization should perform a physical inventory of the property and reconcile the results with fixed asset records at least once every two years to help prevent loss, damage, or theft of the property.
Views of Responsible Officials: The Organization agrees with this finding.