FAC Explorer

Audit 34318

FY End
2022-06-30
Total Expended
$14.97M
Findings
10
Programs
10
Organization: City of Benton Harbor, Michigan (MI)
Year: 2022 Accepted: 2022-12-18
Auditor: Rehmann Robson LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
38324 2022-001 Significant Deficiency Yes BCI
38325 2022-001 Significant Deficiency Yes BCI
38326 2022-001 Significant Deficiency Yes BCI
38327 2022-001 Significant Deficiency Yes BCI
38328 2022-001 Significant Deficiency Yes BCI
614766 2022-001 Significant Deficiency Yes BCI
614767 2022-001 Significant Deficiency Yes BCI
614768 2022-001 Significant Deficiency Yes BCI
614769 2022-001 Significant Deficiency Yes BCI
614770 2022-001 Significant Deficiency Yes BCI

Programs

ALN Program Spent Major Findings
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $4.96M Yes 1
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.75M Yes 1
66.468 Capitalization Grants for Drinking Water State Revolving Funds $949,375 - 0
81.042 Weatherization Assistance for Low-Income Persons $137,177 - 0
14.218 Community Development Block Grants/entitlement Grants $46,053 Yes 1
21.023 Emergency Rental Assistance Program $36,858 - 0
97.044 Assistance to Firefighters Grant $13,506 - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $8,399 - 0
66.458 Capitalization Grants for Clean Water State Revolving Funds $7,397 - 0
93.569 Community Services Block Grant $927 - 0

Contacts

Name Title Type
CKA9Q3H2PXH7 Ellis Mitchell Auditee
2699278457 Paul Matz, Cpa, Cgfm Auditor
No contacts on file

Notes to SEFA

Title: STATE REVOLVING LOAN PROGRAMS Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of the City of Benton Harbor, Michigan (the City) under programs of the federal government for the year ended June 30, 2022. 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 City, it is not intended to and does not present the financial position, changes in net position or cash flows of the City. The City's reporting entity is defined in Note 1 of the City's financial statements. The City's financial statements include the operations of the Twin Cities Area Transportation Authority and the Benton Harbor Housing Commission discretely presented component units, which received federal awards that are not included in the Schedule for the year ended June 30, 2022, as these entities were separately audited. Expenditures reported on the Schedule are reported on the accrual basis of accounting, which is described in Note 1 to the City'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: N Rate Explanation: The auditee did not use the de minimis cost rate. The outstanding balance on Clean Water State Revolving Loan was $3,397,489 as of June 30, 2022. The outstanding balance on Drinking Water State Revolving Loan was $5,083,167 as of June 30, 2022.
Title: RECONCILIATION TO THE BASIC FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of the City of Benton Harbor, Michigan (the City) under programs of the federal government for the year ended June 30, 2022. 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 City, it is not intended to and does not present the financial position, changes in net position or cash flows of the City. The City's reporting entity is defined in Note 1 of the City's financial statements. The City's financial statements include the operations of the Twin Cities Area Transportation Authority and the Benton Harbor Housing Commission discretely presented component units, which received federal awards that are not included in the Schedule for the year ended June 30, 2022, as these entities were separately audited. Expenditures reported on the Schedule are reported on the accrual basis of accounting, which is described in Note 1 to the City'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: N Rate Explanation: The auditee did not use the de minimis cost rate. See the Notes to the SEFA for table.

Finding Details

Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.
Finding 2022-001
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. 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 City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. 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 City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.