FAC Explorer

Audit 321176

FY End
2023-09-30
Total Expended
$840,636
Findings
4
Programs
3
Organization: Lapeer County (MI)
Year: 2023 Accepted: 2024-09-26
Auditor: Uhy LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
498473 2023-001 Material Weakness - I
498474 2023-002 Material Weakness - I
1074915 2023-001 Material Weakness - I
1074916 2023-002 Material Weakness - I

Programs

ALN Program Spent Major Findings
93.696 Certified Community Behavioral Health Clinic Expansion Grants $623,831 Yes 2
93.778 Medical Assistance Program $121,111 - 0
93.958 Block Grants for Community Mental Health Services $12,028 - 0

Contacts

Name Title Type
CET5MYVNZH69 Emma McQuillan Auditee
8102458272 Paul Bailey Auditor
No contacts on file

Notes to SEFA

Title: Note 1- Summary of Significant Accounting Policies Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Lapeer County Community Mental Health Board (the “Board”) for the year ended September 30, 2023. Expenditures reported on the Schedule are reported on the same basis of accounting, the accrual basis, as the financial statements; although the basis for determining when federal awards are expended 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), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this Schedule may differ from amounts presented in or used in the preparation of the financial statements. For purposes of charging indirect costs to federal awards, the Board has elected to use the 10% de minimis cost rate allowed under the Uniform Guidance. The Board did not pass-through federal awards to subrecipients in 2023. Because the Schedule presents only a selected portion of the operations of the Board, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Board. De Minimis Rate Used: Y Rate Explanation: For purposes of charging indirect costs to federal awards, the Board has elected to use the 10% de minimis cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Lapeer County Community Mental Health Board (the “Board”) for the year ended September 30, 2023. Expenditures reported on the Schedule are reported on the same basis of accounting, the accrual basis, as the financial statements; although the basis for determining when federal awards are expended 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), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this Schedule may differ from amounts presented in or used in the preparation of the financial statements. For purposes of charging indirect costs to federal awards, the Board has elected to use the 10% de minimis cost rate allowed under the Uniform Guidance. The Board did not pass-through federal awards to subrecipients in 2023. Because the Schedule presents only a selected portion of the operations of the Board, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Board.
Title: Note 2- Reconciliation to Schedule of Expenditures of Federal Awards Accounting Policies: The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of Lapeer County Community Mental Health Board (the “Board”) for the year ended September 30, 2023. Expenditures reported on the Schedule are reported on the same basis of accounting, the accrual basis, as the financial statements; although the basis for determining when federal awards are expended 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), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in this Schedule may differ from amounts presented in or used in the preparation of the financial statements. For purposes of charging indirect costs to federal awards, the Board has elected to use the 10% de minimis cost rate allowed under the Uniform Guidance. The Board did not pass-through federal awards to subrecipients in 2023. Because the Schedule presents only a selected portion of the operations of the Board, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Board. De Minimis Rate Used: Y Rate Explanation: For purposes of charging indirect costs to federal awards, the Board has elected to use the 10% de minimis cost rate allowed under the Uniform Guidance. See the Notes to the SEFA for chart/table

Finding Details

Finding 2023-001
Procurement Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086491-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: Per 2 CFR 200.318(a), the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. In addition, per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement. Condition: The Board did not utilize federal procurement requirements cited above for the project evaluation and coordination services for the Certified Community Behavioral Health Clinics project. Identification of How Likely Questioned Costs Were Computed: The questioned costs were determined from project evaluation and coordination services billed (federal portion) during the October 1, 2022, through September 29, 2023, period as summarized from the request for disbursement of funds submitted to SAMHSA. Known Questioned Costs: $150,000 Context: We tested the procurement of the one material contract and identified the contract did not follow federal procurement requirements. Cause/Effect: Prior to the Board being awarded of the grant, a bid for grant writing services was procured with the additional question of the availability of project evaluation services being able to be provided. Since the grant writing was procured and the Board decided to contract with the same consulting firm that provided the grant writing, they did not believe they needed to bid the project evaluation and coordination services for this project. The Board did not utilize federal procurement requirements to ensure fair and open competition and reasonable cost for project evaluation and coordination services for the Certified Community Behavioral Health Clinic project. Recommendation: We recommend the Board follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
Finding 2023-002
Evaluating Potential Contractor for Debarment and Suspension Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086491-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Board did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None. Subsequently, the sam.gov website was reviewed to ensure that the contractors were not suspended or debarred. Context: The consultant utilized for the Certified Community Behavior Health Clinic Expansion Grant project was not evaluated. Cause/Effect: The Board currently has a process for suspension and debarment for direct service providers only, and did not have controls in place to comply with suspension and debarment evaluation requirements for the Certified Community Behavioral Health Clinic Expansion Grant or other federal funds outside of direct service providers. Recommendation: We recommend the Board implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
Finding 2023-001
Procurement Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086491-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: Per 2 CFR 200.318(a), the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. In addition, per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement. Condition: The Board did not utilize federal procurement requirements cited above for the project evaluation and coordination services for the Certified Community Behavioral Health Clinics project. Identification of How Likely Questioned Costs Were Computed: The questioned costs were determined from project evaluation and coordination services billed (federal portion) during the October 1, 2022, through September 29, 2023, period as summarized from the request for disbursement of funds submitted to SAMHSA. Known Questioned Costs: $150,000 Context: We tested the procurement of the one material contract and identified the contract did not follow federal procurement requirements. Cause/Effect: Prior to the Board being awarded of the grant, a bid for grant writing services was procured with the additional question of the availability of project evaluation services being able to be provided. Since the grant writing was procured and the Board decided to contract with the same consulting firm that provided the grant writing, they did not believe they needed to bid the project evaluation and coordination services for this project. The Board did not utilize federal procurement requirements to ensure fair and open competition and reasonable cost for project evaluation and coordination services for the Certified Community Behavioral Health Clinic project. Recommendation: We recommend the Board follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
Finding 2023-002
Evaluating Potential Contractor for Debarment and Suspension Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086491-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Board did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None. Subsequently, the sam.gov website was reviewed to ensure that the contractors were not suspended or debarred. Context: The consultant utilized for the Certified Community Behavior Health Clinic Expansion Grant project was not evaluated. Cause/Effect: The Board currently has a process for suspension and debarment for direct service providers only, and did not have controls in place to comply with suspension and debarment evaluation requirements for the Certified Community Behavioral Health Clinic Expansion Grant or other federal funds outside of direct service providers. Recommendation: We recommend the Board implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.