Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, Community Development Block Grants Cluster Federal Award Identification Number and Year - B-21-MC-26-0006 Pass-through Entity - N/A Finding Type - Material noncompliance and material weakness Repeat Finding - Yes, 2021-014 Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement. Condition - During reporting testing, we noted that the City did not file three FFATA reports, and there were five untimely submissions. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City obligated several subawards throughout the year ended June 30,2022,and the reports were due at end of the month plus one additional month after the awards or subaward was obligated. The following table summarizes the transactions examined and the noncompliance identified: Transactions Tested - 10 Subaward Not Reported - 3 Report Not Timely - 5 Subaward Amount Incorrect - 0 Dollar Amount of Tested Transactions - $3,177,529 Subward Not Reported - $806,928 Report Not timely - $2,219,706 Subaward Amount Incorrect - $0 Subaward Missing Key Elements - $0 Cause and Effect - The City's processes did not properly identify the FFATA filing requirements resulting in a delay in filing the report. Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan - In fiscal year 2022, the City created and implemented a Federal Funding Accountability and Transparency Act (FFATA) SOP that included roles and responsibilities and process requirements. Management will finalize the rollout of the policy and implement additional controls to ensure the FFATA filing requirements are met and reporting is timely and accurate.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021 29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Criteria Per 2 CFR 200.331 (b) Contractors. A contract is for the purpose of obtaining goods and services for the nonfederal entity's own use and creates a procurement relationship with the contractor. See the definition of contract in ? 200.1 of this part. Characteristics indicative of a procurement relationship between the nonfederal entity and a contractor are when the contractor: (1) Provides the goods and services within normal business operations (2) Provides similar goods or services to many different purchasers (3) Normally operates in a competitive environment (4) Provides goods or services that are ancillary to the operation of the Federal program (5) Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons Condition - We noted that the City?s contractor was a party to the agreements with the City?s subrecipients. Based on the definition of a subaward as defined by Uniform Guidance (UG), a subaward is provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. Further, a pass-through entity is defined as a nonfederal entity that provides a subaward to a subrecipient to carry out part of a federal program. A contractor is not a pass-through entity. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s contractor selected the City?s 15 subrecipients and entered into a subaward agreement with each of them. In addition to the contractor?s signature, the City was also a signer of the agreement. It was noted that the City performed the monitoring of the 15 subrecipients as required by UG. Cause and Effect - The City?s relationship with the contractor changed recently from a fiduciary relationship to a contractor relationship, and certain responsibilities that were more in line with a subrecipient characteristic were retained in the contract. The City is responsible for evaluating agreements to assess whether a subrecipient or contractor relationship exists. The inclusion of programmatic decisions within an agreement could result in an inappropriate conclusion as to whether a subrecipient or contractor relationship exists and the City not performing appropriate oversight procedures. Recommendation - We recommend that the City review the contract and ensure that the scope of services excludes responsibilities that might apply to a subrecipient rather than a contractor and verify that adequate oversight controls are in place. Views of Responsible Officials and Planned Corrective Actions - The City will implement a process to ensure that its contractors do not enter into subrecipient agreements on behalf of the City. This will be monitored by ensuring that the contractors scope of work does not include solicitating and contracting with organizations as subrecipients. The City will issue its own Notice of Funding Availability (NOFA) application and directly enter into subrecipient agreements with qualified organizations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021-29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The grant agreement with the awarding agency, Health Resources and Services Administration (HRSA), identifies that program income must be treated under the addition method. Per 45 CFR 75.307 (e), program income may be added to the federal award by the federal agency and the nonfederal entity. The program income must be used for the purposes and under the conditions of the federal award. Condition - The city controls did not result in the reporting of program income earned by subrecipients to the funding agency and not reporting the program income and related expenditures in their general ledger and on the SEFA. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s subrecipients earn and report program income to City, and the City monitors the subrecipients? compliance related to the use of the program income; however, the City did not report the program income to its funding agency and did not reflect program income and related expenditures in their general ledger or on the SEFA for the year ended June 30, 2022. Program income earned by subrecipients for fiscal year 2022 totaled approximately $4,800 and was subsequently included on the SEFA as of June 30, 2022. Cause and Effect - The City was aware of the regulations related to program income delegated to the subrecipients but was not aware of the regulations it needed to comply with. As a result, the City did not report the program income to HRSA and did not reflect program income and related expenditures in its general ledger and on the SEFA. The lack of reporting could also result in the appropriate major programs not being selected as a result of the SEFA being understated. Recommendation - We recommend the City evaluate all applicable regulations to determine their responsibility and implement processes and controls in order to be in compliance with the requirements. Views of Responsible Officials and Planned Corrective Actions - The $4,800 program income was reported on the general ledger in FY22 and included in the final FY22 SEFA but after the notification from the auditors. The City will implement a corrective action plan to document the program income requirements and track all awards with program income to help ensure proper and accurate reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021 29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Criteria Per 2 CFR 200.331 (b) Contractors. A contract is for the purpose of obtaining goods and services for the nonfederal entity's own use and creates a procurement relationship with the contractor. See the definition of contract in ? 200.1 of this part. Characteristics indicative of a procurement relationship between the nonfederal entity and a contractor are when the contractor: (1) Provides the goods and services within normal business operations (2) Provides similar goods or services to many different purchasers (3) Normally operates in a competitive environment (4) Provides goods or services that are ancillary to the operation of the Federal program (5) Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons Condition - We noted that the City?s contractor was a party to the agreements with the City?s subrecipients. Based on the definition of a subaward as defined by Uniform Guidance (UG), a subaward is provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. Further, a pass-through entity is defined as a nonfederal entity that provides a subaward to a subrecipient to carry out part of a federal program. A contractor is not a pass-through entity. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s contractor selected the City?s 15 subrecipients and entered into a subaward agreement with each of them. In addition to the contractor?s signature, the City was also a signer of the agreement. It was noted that the City performed the monitoring of the 15 subrecipients as required by UG. Cause and Effect - The City?s relationship with the contractor changed recently from a fiduciary relationship to a contractor relationship, and certain responsibilities that were more in line with a subrecipient characteristic were retained in the contract. The City is responsible for evaluating agreements to assess whether a subrecipient or contractor relationship exists. The inclusion of programmatic decisions within an agreement could result in an inappropriate conclusion as to whether a subrecipient or contractor relationship exists and the City not performing appropriate oversight procedures. Recommendation - We recommend that the City review the contract and ensure that the scope of services excludes responsibilities that might apply to a subrecipient rather than a contractor and verify that adequate oversight controls are in place. Views of Responsible Officials and Planned Corrective Actions - The City will implement a process to ensure that its contractors do not enter into subrecipient agreements on behalf of the City. This will be monitored by ensuring that the contractors scope of work does not include solicitating and contracting with organizations as subrecipients. The City will issue its own Notice of Funding Availability (NOFA) application and directly enter into subrecipient agreements with qualified organizations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021-29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The grant agreement with the awarding agency, Health Resources and Services Administration (HRSA), identifies that program income must be treated under the addition method. Per 45 CFR 75.307 (e), program income may be added to the federal award by the federal agency and the nonfederal entity. The program income must be used for the purposes and under the conditions of the federal award. Condition - The city controls did not result in the reporting of program income earned by subrecipients to the funding agency and not reporting the program income and related expenditures in their general ledger and on the SEFA. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s subrecipients earn and report program income to City, and the City monitors the subrecipients? compliance related to the use of the program income; however, the City did not report the program income to its funding agency and did not reflect program income and related expenditures in their general ledger or on the SEFA for the year ended June 30, 2022. Program income earned by subrecipients for fiscal year 2022 totaled approximately $4,800 and was subsequently included on the SEFA as of June 30, 2022. Cause and Effect - The City was aware of the regulations related to program income delegated to the subrecipients but was not aware of the regulations it needed to comply with. As a result, the City did not report the program income to HRSA and did not reflect program income and related expenditures in its general ledger and on the SEFA. The lack of reporting could also result in the appropriate major programs not being selected as a result of the SEFA being understated. Recommendation - We recommend the City evaluate all applicable regulations to determine their responsibility and implement processes and controls in order to be in compliance with the requirements. Views of Responsible Officials and Planned Corrective Actions - The $4,800 program income was reported on the general ledger in FY22 and included in the final FY22 SEFA but after the notification from the auditors. The City will implement a corrective action plan to document the program income requirements and track all awards with program income to help ensure proper and accurate reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 212MI013W5003, 202MI003W1003, programs years 2020 and 2021 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City of Detroit, Michigan did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor?s staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor?s eligibility determinations. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor?s procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors that pertain to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Corrective Action Plan - The City will implement controls to ensure that health department provides oversight of our contractor and the participant eligibility process. The health department has hired a WIC program director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, Community Development Block Grants Cluster Federal Award Identification Number and Year - B-21-MC-26-0006 Pass-through Entity - N/A Finding Type - Material noncompliance and material weakness Repeat Finding - Yes, 2021-014 Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement. Condition - During reporting testing, we noted that the City did not file three FFATA reports, and there were five untimely submissions. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City obligated several subawards throughout the year ended June 30,2022,and the reports were due at end of the month plus one additional month after the awards or subaward was obligated. The following table summarizes the transactions examined and the noncompliance identified: Transactions Tested - 10 Subaward Not Reported - 3 Report Not Timely - 5 Subaward Amount Incorrect - 0 Dollar Amount of Tested Transactions - $3,177,529 Subward Not Reported - $806,928 Report Not timely - $2,219,706 Subaward Amount Incorrect - $0 Subaward Missing Key Elements - $0 Cause and Effect - The City's processes did not properly identify the FFATA filing requirements resulting in a delay in filing the report. Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan - In fiscal year 2022, the City created and implemented a Federal Funding Accountability and Transparency Act (FFATA) SOP that included roles and responsibilities and process requirements. Management will finalize the rollout of the policy and implement additional controls to ensure the FFATA filing requirements are met and reporting is timely and accurate.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID 19 HOPWA Federal Award Identification Number and Year - MIH20 F001, MIH21 F001, and MIH20 FHW001, Program Years 2020 (includes COVID funding), and 2021 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes-2021 007, 2020 008, 2019 010 Criteria - Per 24 CFR 574.310, except for persons in short term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family?s monthly adjusted gross income; (2) 10 percent of the family?s monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During eligibility testing of a sample of 60, we noted: ? 14 instances where the calculation of rental assistance was incorrect. In 2 instances, the error resulted in an overpayment, and, in 12 instances, the error resulted in an underpayment of benefits. ? 1 instance where the amount paid as rental assistance exceeded the calculated rental assistance. ? 17 instances where there was no evidence of second review of the calculations of rental assistance. Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries. Recommendation - We recommend that the City review its procedures and controls specific to the calculation of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy, and that the payments are consistent with the calculation prior to finalizing the benefits and communicating the same to the participant. Views of Responsible Officials and Planned Corrective Actions - In FY23, the City of Detroit?s Public Health Project Coordinator implemented a review of 100 percent of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The City will also continue to work with its contractor on process improvements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission. The City has written procedures for the use of noncompetitive procurement methods in place, as required by procurement standards within 2 CFR Part 200, Subpart D (Post Federal Award Requirements) and Notice CPD-21-09 issued by the Department of Housing and Urban Development, as well as the Federal Transit Authority Circular 4220.The City?s internal policy requires the Office of Contracting and Procurement (OCP) to notify City Council in writing of basis for the emergency and selection of a particular supplier within one week of procurement and for the OCP to submit the contract for City Council approval within four weeks of procurement. Condition - A contract selected for testing within Emergency Solutions Grant Program that was procured in August 2021 was not communicated to City Council until October 2022. A contract selected for testing within the Federal Transit Cluster that was procured in November 2021 was submitted for City Council approval within the prescribed four weeks; however, OCP did not notify City Council in writing of the basis for the emergency contract within one week of the procurement. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In our sample of one ESG procurements, we noted one instance of noncompliance. In our sample of seven FTC procurements, we noted one instance of noncompliance. Cause and Effect - The City?s controls were not adequate to ensure it followed its internal policy concerning noncompetitive procurements. As a result, there were two instances of noncompliance related to procurement. Recommendation - We recommend the City follow the existing policies and procedures to ensure procurement practices remain in compliance with the City?s internal policies and procedures. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement noncompetitive policy to ensure the required review, controls, and checklist are in place to ensure compliance and all policy steps are followed by staff.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID 19 Federal Award Identification Number and Year - ALN 14.231: E19MC260006, E20MC260006, E20MW260006, E21MC260006 ALN 20.507 and 20.526: All awards included on the schedule under the ALNs Pass through Entity - N/A Finding Type Material weakness 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). Additionally, a nonfederal entity requires a cost price analysis to be performed with every procurement action in excess of the Simplified Acquisition Threshold (2 CFR section 200.324). Condition During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost price analysis. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The contracts identified above was tested among a sample of 15 contracts in total, a sample of 8 for ESG and a sample of 7 for FTC. Cause and Effect - The City?s controls were not adequate to comply with suspension and debarment and cost price analysis requirements. A possible effect is that the City could be responsible for repaying costs charged to the grant if it enters into a transaction with an entity that is suspended or debarred or that the appropriate cost price analysis has not been performed. Recommendation We recommend the City implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions, and, when required, a cost price analysis is performed. Views of Responsible Officials and Planned Corrective Actions - The City will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332 (a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes the following: (1) Federal award identification (i) Subrecipient name (which must match the name associated with its unique entity identifier) (ii) Subrecipient's unique entity identifier (iii) Federal Award Identification Number (FAIN) (iv) Federal award date (see the definition of federal award date in ? 200.1 of this part) of award to the recipient by the federal agency (v) Subaward period of performance start and end date (vi) Subaward budget period start and end date (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity (xii) Assistance Listing Numbers and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listing Numbers at time of disbursement (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the federal award (including if the de minimis rate is charged) per ? 200.414 Condition - The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN), as required per 2 CFR 200.332 (a)(1)(xii). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year, the City passed through CSLFRF funding to three subrecipients. The agreements with the subrecipients included a reference to the applicable regulations provided by the Treasury and all the elements outlined under 2 CFR 200.331 (a)(1) with the exception of the ALN. Cause and Effect - The City?s controls did not ensure that the subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 (a)(1). The lack of information could result in noncompliance by the subrecipient, as well as incorrect SEFA reporting. Recommendation - We recommend the City implement adequate controls to ensure subrecipient agreements included all the required elements, as outlined under 2 CFR 200.332 a)(1). Views of Responsible Officials and Planned Corrective Actions - The City has implemented a process to ensure that all subrecipient agreements contain the federal ALN, as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021 29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Criteria Per 2 CFR 200.331 (b) Contractors. A contract is for the purpose of obtaining goods and services for the nonfederal entity's own use and creates a procurement relationship with the contractor. See the definition of contract in ? 200.1 of this part. Characteristics indicative of a procurement relationship between the nonfederal entity and a contractor are when the contractor: (1) Provides the goods and services within normal business operations (2) Provides similar goods or services to many different purchasers (3) Normally operates in a competitive environment (4) Provides goods or services that are ancillary to the operation of the Federal program (5) Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons Condition - We noted that the City?s contractor was a party to the agreements with the City?s subrecipients. Based on the definition of a subaward as defined by Uniform Guidance (UG), a subaward is provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. Further, a pass-through entity is defined as a nonfederal entity that provides a subaward to a subrecipient to carry out part of a federal program. A contractor is not a pass-through entity. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s contractor selected the City?s 15 subrecipients and entered into a subaward agreement with each of them. In addition to the contractor?s signature, the City was also a signer of the agreement. It was noted that the City performed the monitoring of the 15 subrecipients as required by UG. Cause and Effect - The City?s relationship with the contractor changed recently from a fiduciary relationship to a contractor relationship, and certain responsibilities that were more in line with a subrecipient characteristic were retained in the contract. The City is responsible for evaluating agreements to assess whether a subrecipient or contractor relationship exists. The inclusion of programmatic decisions within an agreement could result in an inappropriate conclusion as to whether a subrecipient or contractor relationship exists and the City not performing appropriate oversight procedures. Recommendation - We recommend that the City review the contract and ensure that the scope of services excludes responsibilities that might apply to a subrecipient rather than a contractor and verify that adequate oversight controls are in place. Views of Responsible Officials and Planned Corrective Actions - The City will implement a process to ensure that its contractors do not enter into subrecipient agreements on behalf of the City. This will be monitored by ensuring that the contractors scope of work does not include solicitating and contracting with organizations as subrecipients. The City will issue its own Notice of Funding Availability (NOFA) application and directly enter into subrecipient agreements with qualified organizations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021-29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The grant agreement with the awarding agency, Health Resources and Services Administration (HRSA), identifies that program income must be treated under the addition method. Per 45 CFR 75.307 (e), program income may be added to the federal award by the federal agency and the nonfederal entity. The program income must be used for the purposes and under the conditions of the federal award. Condition - The city controls did not result in the reporting of program income earned by subrecipients to the funding agency and not reporting the program income and related expenditures in their general ledger and on the SEFA. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s subrecipients earn and report program income to City, and the City monitors the subrecipients? compliance related to the use of the program income; however, the City did not report the program income to its funding agency and did not reflect program income and related expenditures in their general ledger or on the SEFA for the year ended June 30, 2022. Program income earned by subrecipients for fiscal year 2022 totaled approximately $4,800 and was subsequently included on the SEFA as of June 30, 2022. Cause and Effect - The City was aware of the regulations related to program income delegated to the subrecipients but was not aware of the regulations it needed to comply with. As a result, the City did not report the program income to HRSA and did not reflect program income and related expenditures in its general ledger and on the SEFA. The lack of reporting could also result in the appropriate major programs not being selected as a result of the SEFA being understated. Recommendation - We recommend the City evaluate all applicable regulations to determine their responsibility and implement processes and controls in order to be in compliance with the requirements. Views of Responsible Officials and Planned Corrective Actions - The $4,800 program income was reported on the general ledger in FY22 and included in the final FY22 SEFA but after the notification from the auditors. The City will implement a corrective action plan to document the program income requirements and track all awards with program income to help ensure proper and accurate reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021 29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Criteria Per 2 CFR 200.331 (b) Contractors. A contract is for the purpose of obtaining goods and services for the nonfederal entity's own use and creates a procurement relationship with the contractor. See the definition of contract in ? 200.1 of this part. Characteristics indicative of a procurement relationship between the nonfederal entity and a contractor are when the contractor: (1) Provides the goods and services within normal business operations (2) Provides similar goods or services to many different purchasers (3) Normally operates in a competitive environment (4) Provides goods or services that are ancillary to the operation of the Federal program (5) Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons Condition - We noted that the City?s contractor was a party to the agreements with the City?s subrecipients. Based on the definition of a subaward as defined by Uniform Guidance (UG), a subaward is provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. Further, a pass-through entity is defined as a nonfederal entity that provides a subaward to a subrecipient to carry out part of a federal program. A contractor is not a pass-through entity. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s contractor selected the City?s 15 subrecipients and entered into a subaward agreement with each of them. In addition to the contractor?s signature, the City was also a signer of the agreement. It was noted that the City performed the monitoring of the 15 subrecipients as required by UG. Cause and Effect - The City?s relationship with the contractor changed recently from a fiduciary relationship to a contractor relationship, and certain responsibilities that were more in line with a subrecipient characteristic were retained in the contract. The City is responsible for evaluating agreements to assess whether a subrecipient or contractor relationship exists. The inclusion of programmatic decisions within an agreement could result in an inappropriate conclusion as to whether a subrecipient or contractor relationship exists and the City not performing appropriate oversight procedures. Recommendation - We recommend that the City review the contract and ensure that the scope of services excludes responsibilities that might apply to a subrecipient rather than a contractor and verify that adequate oversight controls are in place. Views of Responsible Officials and Planned Corrective Actions - The City will implement a process to ensure that its contractors do not enter into subrecipient agreements on behalf of the City. This will be monitored by ensuring that the contractors scope of work does not include solicitating and contracting with organizations as subrecipients. The City will issue its own Notice of Funding Availability (NOFA) application and directly enter into subrecipient agreements with qualified organizations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants Federal Award Identification Number and Year - H89HA00021-29-01, H89HA00021-30-00 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The grant agreement with the awarding agency, Health Resources and Services Administration (HRSA), identifies that program income must be treated under the addition method. Per 45 CFR 75.307 (e), program income may be added to the federal award by the federal agency and the nonfederal entity. The program income must be used for the purposes and under the conditions of the federal award. Condition - The city controls did not result in the reporting of program income earned by subrecipients to the funding agency and not reporting the program income and related expenditures in their general ledger and on the SEFA. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City?s subrecipients earn and report program income to City, and the City monitors the subrecipients? compliance related to the use of the program income; however, the City did not report the program income to its funding agency and did not reflect program income and related expenditures in their general ledger or on the SEFA for the year ended June 30, 2022. Program income earned by subrecipients for fiscal year 2022 totaled approximately $4,800 and was subsequently included on the SEFA as of June 30, 2022. Cause and Effect - The City was aware of the regulations related to program income delegated to the subrecipients but was not aware of the regulations it needed to comply with. As a result, the City did not report the program income to HRSA and did not reflect program income and related expenditures in its general ledger and on the SEFA. The lack of reporting could also result in the appropriate major programs not being selected as a result of the SEFA being understated. Recommendation - We recommend the City evaluate all applicable regulations to determine their responsibility and implement processes and controls in order to be in compliance with the requirements. Views of Responsible Officials and Planned Corrective Actions - The $4,800 program income was reported on the general ledger in FY22 and included in the final FY22 SEFA but after the notification from the auditors. The City will implement a corrective action plan to document the program income requirements and track all awards with program income to help ensure proper and accurate reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.