Finding 1223691 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-07-15
Audit: 407192
Organization: Lapeer County (MI)

AI Summary

  • Core Issue: The CMHSP failed to follow procurement rules for a contract related to project evaluation, leading to a repeat finding from last year's audit.
  • Impacted Requirements: Non-compliance with 2 CFR section 200.318, which mandates documented procurement procedures that align with federal and local laws.
  • Recommended Follow-Up: CMHSP should update its procurement policies to ensure compliance with federal requirements for future contracts, as management agrees with this recommendation.

Finding Text

2025-002 PROCUREMENT (repeat comment) Type: Material weakness in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion Grants (CCBHC) Criteria: Per 2 CFR section 200.318, the non-Federal entity, “…must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327.” Condition: During testing, it was noted that the CMHSP had not followed procurement requirements for the contract entered into for project evaluation and coordination services. This is the same contract that produced a material finding in the prior year single audit. Cause/Effect: Management oversight. Questioned Cost: $150,000 – the amount paid during the fiscal year pursuant to contract in question. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that all federal requirements for procurements are followed for future contracts entered into with federal funds. Management’s Resp: Management is in agreement with this recommendation. Also, the grantor was notified of this finding and has notified the CMHSP that there is no elevated level of risk moving forward through the remainder of the grant cycle.

Corrective Action Plan

2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Responsible Party: Emma McQuillan, Chief Financial Officer Completion Date: 12/5/2024

Categories

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1223692 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $990,917
93.778 GRANTS TO STATES FOR MEDICAID $133,555
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $80,472