Finding Text
2024-003 – Written Policies Required by the Uniform Grant Guidance (Repeat). Finding Type. Immaterial noncompliance. Federal program(s) U.S. Department of Education - COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425W); Passed through the Michigan Department of Education; All project numbers. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302(6)); 2) Allowability of costs charged to federal programs (§200.302(7)); and 3) Compensation (personnel and benefits policy) (§200.430 and §200.431). Condition. Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs have been questioned as a result of this finding. Recommendation. We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. View of Responsible Officials. As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year. Responsible Official. Chief Financial Officer. Estimated Completion Date. June 30, 2025.