Finding 1219175 (2025-003)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-06-26
Audit: 405111

Finding Text

Written Policies Required by the Uniform Grant Guidance Finding Type. Immaterial noncompliance Federal program(s) U.S. Department of Treasury - Coronavirus State & Local Fiscal Recovery Funds (ALN 21.027); Direct award and amounts passed through the Michigan Department of Environment, Great Lake, and Energy; All project numbers. U.S. Environmental Protection Agency - Congressionally Mandated Projects (ALN 66.202); Direct award; 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 Township 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 Township did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We are aware that the Township is evaluating options using internal and external resources to take corrective action. We recommend that the Township proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. View of Responsible Officials. View of Responsible Officials. As noted in the auditor recommendation, the Township is in the process of evaluating a draft grant administration policy, which will address items #1 and #2 (payments and allowability of costs charged to federal programs). Item #3 (compensation) will be addressed via review and modification as needed of the Township’s personnel manual to ensure compliance.

Corrective Action Plan

Written Policies Required by the Uniform Guidance Auditor Description of Criteria, Condition, and Effect: 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). Although the Township has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the Township did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation: We are aware that the Township is evaluating options using internal and external resources to take corrective action. We recommend that the Township proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. Corrective Action: As noted in the auditor recommendation, the Township is in the process of evaluating a draft grant administration policy, which will address items #1 and #2 (payments and allowability of costs charged to federal programs). Item #3 (compensation) will be addressed via review and modification as needed of the Township’s personnel manual to ensure compliance. Responsible Persons: Karen Trombley, Accounting Coordinator; Sarah Mistretta, Human Resources Director Anticipated Completion Date: December 31, 2026

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1219171 2025-001
    Material Weakness Repeat
  • 1219172 2025-002
    Material Weakness Repeat
  • 1219173 2025-002
    Material Weakness Repeat
  • 1219174 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $2.59M
66.202 CONGRESSIONALLY MANDATED PROJECTS $1.60M
20.614 NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION (NHTSA) DISCRETIONARY SAFETY GRANTS AND COOPERATIVE AGREEMENTS $24,912
97.067 HOMELAND SECURITY GRANT PROGRAM $18,049
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $8,370
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $6,080
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $3,280