Finding Text
2023-001 Written Financial Policies
ALN 84.215: Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and
Congressionally Directed, Spending For Elementary and Secondary Education Community Projects
U.S. Department of Education
Finding Type: Material Weakness and Material Noncompliance
Condition: There were no formal, documented federal policies and procedures in place for December 31, 2023,
as required by the Uniform Guidance.
Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant
awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1)
Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds
and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including
bidding and conflict of interest policy) (§200.318); and 3) Allowability of costs charged to federal programs
(§200.302 (7)).
Cause: Documented federal policies and procedures were not created and implemented by the Organization.
Effect: As the result of this condition, Boys & Girls Clubs of Greater Southwest Michigan did not fully comply
with the Uniform Guidance applicable to the major federal program.
Recommendation: We recommend that the Organization prepare the required written policies and procedures
as soon as practical.
Organization’s Response: The Organization concurs with the facts of this finding and is in the process of
implementing documented federal policies and procedures.