Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster Community Development Block Grant
Federal Award Identification Number and Year N/A
Pass through Entity ALN 14.218 Wayne County
Finding Type Material weakness
Repeat Finding Yes
2022 002
Criteria The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of Federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule.
Condition The schedule of expenditures of federal awards (SEFA) was not accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context During the fiscal year ended September 30, 2023, the City expended approximately $921,000 of federal funding. The initial draft of the SEFA included the following inaccuracies:
ALN 66.818 The expenditures reported on the SEFA were understated by $689,255.
ALN 14.218 The expenditures reported on the SEFA were understated by $55,192.
The errors noted above have been corrected on the SEFA as of September 30, 2023.
Cause and Effect Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the understatement of federal expenditures. Additionally, the understatement of federal expenditures on the SEFA resulted in the incorrect conclusion that federal activity was below $750,000 and, therefore, a single audit was not needed.
Recommendation We recommend the City implement a process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan The City will review its process for identifying and communicating Federal Grant expenditures to its auditors.
Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster Community Development Block Grant
Federal Award Identification Number and Year N/A
Pass through Entity ALN 14.218 Wayne County
Finding Type Material weakness
Repeat Finding Yes
2022 002
Criteria The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of Federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule.
Condition The schedule of expenditures of federal awards (SEFA) was not accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context During the fiscal year ended September 30, 2023, the City expended approximately $921,000 of federal funding. The initial draft of the SEFA included the following inaccuracies:
ALN 66.818 The expenditures reported on the SEFA were understated by $689,255.
ALN 14.218 The expenditures reported on the SEFA were understated by $55,192.
The errors noted above have been corrected on the SEFA as of September 30, 2023.
Cause and Effect Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the understatement of federal expenditures. Additionally, the understatement of federal expenditures on the SEFA resulted in the incorrect conclusion that federal activity was below $750,000 and, therefore, a single audit was not needed.
Recommendation We recommend the City implement a process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan The City will review its process for identifying and communicating Federal Grant expenditures to its auditors.
Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 003
Criteria In accordance with the Closeout Agreement dated July 20, 2012, the City is required to annually provide a report to the U.S. Environmental Protection Agency (EPA) on the use of the program income from the Assistance Agreement.
Condition The City did not submit the required annual report related to use of program income.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context Program income was generated from an award that was closed out in 2012. The City first used the program income during the fiscal year ending September 30, 2022, with additional program income used during the fiscal year ending September 30, 2023.
Cause and Effect Since the program income was not used for the first ten years after the closeout of the award, the City did not have adequate oversight over original program requirements. As a result, they missed the reporting requirement.
Recommendation We recommend the City implement a process to ensure all reporting requirements are tracked and completed.
Views of Responsible Officials and Planned Corrective Actions The City will work with the EPA to determine how to report the use of program income.
Assistance Listing, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria In accordance with 31 CFR Part 35, section IV "Program Administrative Provisions," subsection "H. Reporting," recipients are required to submit periodic Project and Expenditure Reports.
Condition The City submitted the required Project and Expenditure Report, but the amount reported in March 2023 as cumulative expenditures was the City's total award amount rather than the amount spent to date.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context The total amount reported as cumulative expenditures was $2,612,400.50, which represented the City's total award amount. The actual cumulative expenditures incurred through March 2023 were $92,551.
Cause and Effect The City misinterpreted the information required on the form. As a result, they included the total award amount rather than the actual cumulative expenditures.
Recommendation We recommend the City implement a process to ensure reports are reviewed for accuracy prior to submission.
Views of Responsible Officials and Planned Corrective Actions The City will correct the reports that have been submitted and review future reports to ensure the appropriate expenditures are disclosed.
Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster Community Development Block Grant
Federal Award Identification Number and Year N/A
Pass through Entity ALN 14.218 Wayne County
Finding Type Material weakness
Repeat Finding Yes
2022 002
Criteria The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of Federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule.
Condition The schedule of expenditures of federal awards (SEFA) was not accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context During the fiscal year ended September 30, 2023, the City expended approximately $921,000 of federal funding. The initial draft of the SEFA included the following inaccuracies:
ALN 66.818 The expenditures reported on the SEFA were understated by $689,255.
ALN 14.218 The expenditures reported on the SEFA were understated by $55,192.
The errors noted above have been corrected on the SEFA as of September 30, 2023.
Cause and Effect Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the understatement of federal expenditures. Additionally, the understatement of federal expenditures on the SEFA resulted in the incorrect conclusion that federal activity was below $750,000 and, therefore, a single audit was not needed.
Recommendation We recommend the City implement a process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan The City will review its process for identifying and communicating Federal Grant expenditures to its auditors.
Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster Community Development Block Grant
Federal Award Identification Number and Year N/A
Pass through Entity ALN 14.218 Wayne County
Finding Type Material weakness
Repeat Finding Yes
2022 002
Criteria The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of Federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule.
Condition The schedule of expenditures of federal awards (SEFA) was not accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context During the fiscal year ended September 30, 2023, the City expended approximately $921,000 of federal funding. The initial draft of the SEFA included the following inaccuracies:
ALN 66.818 The expenditures reported on the SEFA were understated by $689,255.
ALN 14.218 The expenditures reported on the SEFA were understated by $55,192.
The errors noted above have been corrected on the SEFA as of September 30, 2023.
Cause and Effect Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the understatement of federal expenditures. Additionally, the understatement of federal expenditures on the SEFA resulted in the incorrect conclusion that federal activity was below $750,000 and, therefore, a single audit was not needed.
Recommendation We recommend the City implement a process to ensure that the SEFA is complete and accurate.
Views of Responsible Officials and Corrective Action Plan The City will review its process for identifying and communicating Federal Grant expenditures to its auditors.
Assistance Listing, Federal Agency, and Program Name 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 003
Criteria In accordance with the Closeout Agreement dated July 20, 2012, the City is required to annually provide a report to the U.S. Environmental Protection Agency (EPA) on the use of the program income from the Assistance Agreement.
Condition The City did not submit the required annual report related to use of program income.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context Program income was generated from an award that was closed out in 2012. The City first used the program income during the fiscal year ending September 30, 2022, with additional program income used during the fiscal year ending September 30, 2023.
Cause and Effect Since the program income was not used for the first ten years after the closeout of the award, the City did not have adequate oversight over original program requirements. As a result, they missed the reporting requirement.
Recommendation We recommend the City implement a process to ensure all reporting requirements are tracked and completed.
Views of Responsible Officials and Planned Corrective Actions The City will work with the EPA to determine how to report the use of program income.
Assistance Listing, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year N/A
Pass through Entity N/A
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria In accordance with 31 CFR Part 35, section IV "Program Administrative Provisions," subsection "H. Reporting," recipients are required to submit periodic Project and Expenditure Reports.
Condition The City submitted the required Project and Expenditure Report, but the amount reported in March 2023 as cumulative expenditures was the City's total award amount rather than the amount spent to date.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A
Context The total amount reported as cumulative expenditures was $2,612,400.50, which represented the City's total award amount. The actual cumulative expenditures incurred through March 2023 were $92,551.
Cause and Effect The City misinterpreted the information required on the form. As a result, they included the total award amount rather than the actual cumulative expenditures.
Recommendation We recommend the City implement a process to ensure reports are reviewed for accuracy prior to submission.
Views of Responsible Officials and Planned Corrective Actions The City will correct the reports that have been submitted and review future reports to ensure the appropriate expenditures are disclosed.