Audit 405078

Written Policies Required by the Uniform Grant Guidance Finding Type. Immaterial noncompliance Federal program(s) U.S. Department of Treasury - Coronavirus State & Local Fiscal Recovery Funds (ALN 21.027); Direct award and amounts passed hrough the Southeast Michigan Community Alliance; All project numbers. U.S. Department of Health and Human Services - Child Support Enforcement (ALN 93.563); Pass-through award; All project numbers. 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: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431). Condition. Although the County has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. 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 County did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We are aware that the County is evaluating options using internal and external resources to take corrective action. We recommend that the County proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. View of Responsible Officials. The County will proceed with its selected option no later than the end of the next fiscal year.