2024-005 Written Policies Required by the Uniform Grant Guidance
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Immaterial noncompliance
Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded to have written policies pertaining to allowability of costs, payments, and compensation charged to federal programs (§200.302(7)).
Condition: A formal written policy covering allowable costs, conflict of interest and procurement has not been updated in accordance with 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: The lack of written policies could result in costs or transactions that would be nonallowable for a federal program.
Questioned Costs: None
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village Council should, as soon as possible, adopt written policies, as required by Uniform Guidance, for allowable costs, conflict of interest and procurement.
Views of Responsible Officials: The Village does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. However, corrective action will be done whereby the written policies will be prepared and adopted for the future.
2024-006 Suspension and Debarment
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Material weakness and material noncompliance
Criteria: Per 2 CRF Section 180.300, recipients must have procedures in place for verifying that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded.
Condition: The Village had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred.
Cause: There were no controls in place to ensure vendors are not suspended, debarred, or otherwise excluded.
Effect: The Village risks entering into contracts with excluded parties, which would be considered noncompliance with the Uniform Guidance.
Questioned Costs: None. Although there was no verification that the contractors were not suspended or debarred prior to the audit, a subsequent check was performed to verify the vendor was not suspended or debarred.
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village Council should, as soon as possible, update its policies to include controls for verifying contractors are not suspended or debarred. Although this is a requirement only for contracts involving the use of federal funds, the Village may want to update its policies over all procurements, not just those related to federally funded projects.
Views of Responsible Officials: The Village’s engineer, Wade Trim, has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, as part of Federal Grant Funding implementation, the Village will ensure that vendors are not debarred or suspended from federal funding awards, whether they check the list themselves or have the engineer do it as part of the bidding process.
2024-007 Reporting
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Immaterial noncompliance
Criteria: Per 31 CFR Section 35 an accurate and complete Project and Expenditure Report is due 30 days after the close of the reporting period.
Condition: The Village did not have adequate controls in place to submit the annual Project and Expenditure Report for the reporting period ended March 31, 2024, within 30 days of the close of the reporting period. The Village also did not complete the report accurately, as the contractor was listed as a subrecipient, which is incorrect, and the incorrect project start date was listed on the report.
Cause: The previous Village Clerk was the one who has filed the report in the past, who is no longer employed at the Village. The filing deadline did not come to the Village’s attention until close to the reporting deadline, which at the time, the Village did not have the appropriate login information to sam.gov to be able to file the report. The Village also had a misunderstanding of what the definition of a subrecipient was and the incorrect project start date was a typo.
Effect: The Village did not submit the annual Project and Expenditure Report timely or accurately.
Questioned Costs: None. The report was filed as soon as the Village was able to get accurate login information to sam.gov.
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village should build a timeline for preparation and completion of the annual Project and Expenditure Report to ensure timely filing. We also urge the Village to review the report carefully in the future and get a complete understanding of how to file the report to avoid any mistakes in the future.
Views of Responsible Officials: The Village is now aware of the reporting deadlines. It was also brought to the attention of the Village the inaccuracies in the report. Now that the Village has the proper login information and understanding of how to accurately complete the annual Project and Expenditure Report, they will ensure it gets filed timely and accurately in the future.
2024-005 Written Policies Required by the Uniform Grant Guidance
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Immaterial noncompliance
Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded to have written policies pertaining to allowability of costs, payments, and compensation charged to federal programs (§200.302(7)).
Condition: A formal written policy covering allowable costs, conflict of interest and procurement has not been updated in accordance with 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: The lack of written policies could result in costs or transactions that would be nonallowable for a federal program.
Questioned Costs: None
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village Council should, as soon as possible, adopt written policies, as required by Uniform Guidance, for allowable costs, conflict of interest and procurement.
Views of Responsible Officials: The Village does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. However, corrective action will be done whereby the written policies will be prepared and adopted for the future.
2024-006 Suspension and Debarment
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Material weakness and material noncompliance
Criteria: Per 2 CRF Section 180.300, recipients must have procedures in place for verifying that an entity with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded.
Condition: The Village had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred.
Cause: There were no controls in place to ensure vendors are not suspended, debarred, or otherwise excluded.
Effect: The Village risks entering into contracts with excluded parties, which would be considered noncompliance with the Uniform Guidance.
Questioned Costs: None. Although there was no verification that the contractors were not suspended or debarred prior to the audit, a subsequent check was performed to verify the vendor was not suspended or debarred.
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village Council should, as soon as possible, update its policies to include controls for verifying contractors are not suspended or debarred. Although this is a requirement only for contracts involving the use of federal funds, the Village may want to update its policies over all procurements, not just those related to federally funded projects.
Views of Responsible Officials: The Village’s engineer, Wade Trim, has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, as part of Federal Grant Funding implementation, the Village will ensure that vendors are not debarred or suspended from federal funding awards, whether they check the list themselves or have the engineer do it as part of the bidding process.
2024-007 Reporting
Program Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Treasury
Federal Award Number: N/A
Federal Award Year: Fiscal year 2024
Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) and Grand Traverse County
Type of Compliance: Immaterial noncompliance
Criteria: Per 31 CFR Section 35 an accurate and complete Project and Expenditure Report is due 30 days after the close of the reporting period.
Condition: The Village did not have adequate controls in place to submit the annual Project and Expenditure Report for the reporting period ended March 31, 2024, within 30 days of the close of the reporting period. The Village also did not complete the report accurately, as the contractor was listed as a subrecipient, which is incorrect, and the incorrect project start date was listed on the report.
Cause: The previous Village Clerk was the one who has filed the report in the past, who is no longer employed at the Village. The filing deadline did not come to the Village’s attention until close to the reporting deadline, which at the time, the Village did not have the appropriate login information to sam.gov to be able to file the report. The Village also had a misunderstanding of what the definition of a subrecipient was and the incorrect project start date was a typo.
Effect: The Village did not submit the annual Project and Expenditure Report timely or accurately.
Questioned Costs: None. The report was filed as soon as the Village was able to get accurate login information to sam.gov.
Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding.
Identification of Repeat Findings: None
Recommendations: The Village should build a timeline for preparation and completion of the annual Project and Expenditure Report to ensure timely filing. We also urge the Village to review the report carefully in the future and get a complete understanding of how to file the report to avoid any mistakes in the future.
Views of Responsible Officials: The Village is now aware of the reporting deadlines. It was also brought to the attention of the Village the inaccuracies in the report. Now that the Village has the proper login information and understanding of how to accurately complete the annual Project and Expenditure Report, they will ensure it gets filed timely and accurately in the future.