Finding Text
2024-001 - Written Policies Required by the Uniform Grant Guidance
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles, Cash Management, Procurement).
Federal program(s)
U.S. Department of Treasury -
COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) (ALN 21.027); Passed through Michigan Strategic Fund and Southwest Michigan First Corporation; 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) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302(7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474).
Condition. Although the Organization has processes in place to cover these areas, there are no formal written policies covering payments, procurement, allowability of costs, compensation, and travel costs in accordance with the Uniform Guidance.
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 Organization did not fully comply with the Uniform Guidance applicable to the above noted grants.
Questioned Costs. No costs were questioned as a result of this finding.
Recommendation. We recommend that the Organization develop and implement the required policies as soon as practical.
View of Responsible Officials. Management is in agreement and has prepared a Corrective Action Plan.