Finding Text
Assistance Listing, Federal Agency, and Program Name - 21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, ADN to BSN Completion Grant Program
Federal Award Identification Number and Year - SLFRP0127, 2023 2026
Pass-through Entity - Michigan Department of Labor and Economic Opportunity
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 (COSO).
Costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E.
Condition - The College's internal control in place for manual journal entries did not identify unallowable costs reported in the SEFA.
Questioned Costs - $326,781
Identification of How Questioned Costs Were Computed - Questioned costs are made up of unallowable direct costs of $233,415 and the related indirect cost at 40 percent of $93,366, totaling $326,781.
Context - A manual journal entry reviewed and approved included unallowable costs, which also impacted the determination of indirect costs charged to the grant in a separate manual journal entry. Therefore, the error is made up of two manual journal entries selected for testing out of 40 total expenditures. The error represented 36 percent of the original amount reported on the SEFA, or $880,303. As a result, $326,781 was removed from the SEFA.
Cause and Effect - Due to an ineffective review of manual journal entries, the grant expenditures reported to the grantor and the amount reported on the original SEFA provided by management for the grant were overstated.
Recommendation - We recommend an effective review of manual journal entries be put in place.
Views of Responsible Officials and Planned Corrective Actions - While the College currently has controls in place to review all manual journal entries, we will adjust our review process going forward to incorporate additional oversight for any manual journal entries impacting federal grants. Going forward, the controller will review all manual journal entries impacting federal grants, and the vice president of finance will provide a second level review of any such entries that equal or exceed $50,000.