Finding 382658 (2022-007)

Material Weakness Repeat Finding
Requirement
BL
Questioned Costs
-
Year
2022
Accepted
2024-03-20
Audit: 296246
Organization: County of Delta (MI)

AI Summary

  • Core Issue: Delta County lacks written policies for managing federal awards, violating Uniform Guidance requirements.
  • Impacted Requirements: Policies are needed for advance payments, allowable costs, compensation, travel costs, and procurement procedures.
  • Recommended Follow-Up: The County should create formal written policies and clarify responsibilities with the State and consultants promptly.

Finding Text

2022-007 – Written Policies Required by the Uniform Guidance (repeat Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and Allowable Costs/Cost Principles) Federal Program: U.S. Department of Transportation – Airport Improvement Program (AL #20.106); all project numbers and U.S. Department of Treasury – Coronavirus State and Local Fiscal Recovery Funds (AL #21.027) Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards specific to the Airport or for federal awards in general. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant on or after December 26, 2014 to have written policies pertaining to: 1) advance payments and reimbursements; 2) determination of allowable costs; 3) compensation (personnel and benefits policies); 4) travel costs; and 5) procurement procedures. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Condition: The County does not have processes in place to conform to all of the requirements in the Uniform Guidance. There are no formal written policies in place specifically related to the Airport. Additionally, the Airport does not have a clear determination of the assignment of responsibilities between Airport management, Michigan Department of Transportation (the State) and other consultants. Cause: The County has not reviewed and updated its policies and procedures for continued changes in grants and the Uniform Guidance. The Airport grants operate outside of the general County processes and internal control system given the administration assistance provided by the State and other consultants. Also, Airport management has experienced significant turnover. Effect: As a result of this condition, the County did not fully comply with the Uniform Guidance. Questioned Costs: No costs have been questioned as a result of this finding. Recommendation: We recommend that the County and the Airport adopt formal written policies covering these areas as soon as practical. The Airport should also formalize responsibilities with the State and other consultants. Views of Responsible Officials: The County will work to update policies and procedures and to formalize responsibilities.

Categories

Allowable Costs / Cost Principles Cash Management Procurement, Suspension & Debarment Material Weakness Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 382653 2022-006
    Material Weakness Repeat
  • 382654 2022-006
    Material Weakness Repeat
  • 382655 2022-006
    Material Weakness Repeat
  • 382656 2022-007
    Material Weakness Repeat
  • 382657 2022-007
    Material Weakness Repeat
  • 382659 2022-008
    Material Weakness
  • 382660 2022-008
    Material Weakness
  • 382661 2022-009
    Significant Deficiency
  • 382662 2022-010
    Significant Deficiency
  • 959095 2022-006
    Material Weakness Repeat
  • 959096 2022-006
    Material Weakness Repeat
  • 959097 2022-006
    Material Weakness Repeat
  • 959098 2022-007
    Material Weakness Repeat
  • 959099 2022-007
    Material Weakness Repeat
  • 959100 2022-007
    Material Weakness Repeat
  • 959101 2022-008
    Material Weakness
  • 959102 2022-008
    Material Weakness
  • 959103 2022-009
    Significant Deficiency
  • 959104 2022-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.38M
20.106 Airport Improvement Program $1.01M
15.226 Payments in Lieu of Taxes $411,258
10.665 Schools and Roads - Grants to States $228,469
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $63,519
16.922 Equitable Sharing Program $51,904
93.563 Child Support Enforcement $48,598
16.575 Crime Victim Assistance $39,186
16.738 Edward Byrne Memorial Justice Assistance Grant Program $38,227
97.012 Boating Safety Financial Assistance $18,400
93.658 Foster Care_title IV-E $14,174
97.042 Emergency Management Performance Grants $10,898
16.034 Coronavirus Emergency Supplemental Funding Program $4,890
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $3,612
97.067 Homeland Security Grant Program $201