Finding Text
2025-004 Written Policies Required by the Uniform Grant Guidance Program Title: Water Infrastructure Improvements for the Nation Small and Underserved Communities Emerging Contaminants Grant Program Assistance Listing Number: 66.442 Federal Agency: U.S. Environmental Protection Agency (EPA) Federal Award Number: N/A Federal Award Year: Fiscal year 2025 Pass-Through Entities: Michigan Department of Environment, Great Lakes, and Energy (EGLE) Type of Compliance: Immaterial noncompliance Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded to have written policies pertaining to allowability of costs, payments, and compensation charged to federal programs (§200.302(7)). Condition: A formal written policy covering allowable costs, conflict of interest and procurement has not been updated 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: The lack of written policies could result in costs or transactions that would be nonallowable for a federal program. Questioned Costs: None Perspective Information: The finding appears to be an isolated instance. No sampling was necessary to determine this finding. Identification of Repeat Findings: None Recommendations: The Township Board should, as soon as possible, adopt written policies, as required by Uniform Guidance, for allowable costs, conflict of interest, and procurement. Views of Responsible Officials: The Township does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. However, corrective action will be done whereby the written policies will be prepared and adopted for the future.