FAC Explorer

Finding 394735 (2023-015)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-04-25
Audit: 304593
Organization: Charter County of Wayne, Michigan (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The County failed to submit required cost allocation plans for self-insurance and annual chargebacks, leading to a material weakness and noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR 200 Appendix V is necessary for major local governments receiving over $100 million in federal awards, which the County became after 2020.
  • Recommended Follow-up: The County should review 2 CFR 200 requirements, document its cost allocation methodologies, and ensure timely submission of plans to the federal cognizant agency.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 14.218 - U.S. Department of Housing and Urban Development (HUD) - CDBG - Entitlement Grants Cluster - Community Development Block Grants/Entitlement Grants 93.563 - Title IV D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) 10.557, U.S. Department of Agriculture - WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year - CDBG - B-21-UC-26-0003 and B-22-UC-26-0003 CSE - CSCOM-17-82003 WIC - E20233245-00 and E20234077-00 Pass-through Entity - CDBG - N/A, direct funded CSE - Michigan Department of Health and Human Services WIC - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-014 Criteria - 2 CFR Appendix V to Part 200 requires each major local government, defined as a local government that receives more than $100 million in direct federal awards, to submit annually to its federal cognizant agency a cost allocation plan whereby central service costs can be identified and assigned to benefited activities on a reasonable and consistent basis. Condition - Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County’s self-insurance cost allocation process and annual chargeback plan. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there were no questioned costs Context - During our review of the County’s process for allocating self insurance costs across the various departments and the annual chargeback plan, we noted the County did not submit its plan for self insurance costs or its annual chargeback plan used to allocate expenditures to the federal grants identified above for the fiscal year ended September 30, 2023 prior to the allocation of these costs. The underlying costs and the allocation methodology were allowable and reasonable, as supported by documentation, thus creating no questioned costs. Beginning in 2020 with the influx of COVID-19 funding, the County received direct funded awards in excess of $100 million, therefore becoming a major local government. Prior to 2020, the County was only required to develop a cost allocation plan in accordance with 2 CFR 200 and maintain the plan and related supporting documentation for audit. Cause and Effect - Procedures and controls in place were not adequate to identify that the County became a major local government, requiring different documentation and submission requirements for self insurance cost allocation process and annual chargeback plan. As a result, no plans were submitted to the cognizant agency for approval. Recommendation - We recommend the County review 2 CFR 200, including the applicable appendixes, to assess the submission and documentation requirements for all cost allocation methodologies. Additionally, we recommend that the County document its methodology for allocating self insurance costs and annual chargeback costs across the various departments, including formalizing its documentation surrounding procedures and controls. Further, we recommend the County implement a process for ensuring these plans are submitted to a federal cognizant agency for approval. Views of Responsible Officials and Planned Corrective Actions - Management communicated with the cognizant agency which confirmed in November 2021, OMB issued guidance relating to CARES Act funding and its effect on indirect cost. Part of this guidance stated that “CARES Act funding should not be included toward the threshold amount for indirect cost submission required in 2 C.F.R. part 200, Appendix VII, paragraph D.1.b”. Therefore, County governments that met the $100 million threshold as a result of CARES Act funding are not required to submit their Central Service Cost Allocation Plan for approval. The CARES Act funding would have increased the County’s funding in excess of $100 million, which should not have been a part of the determination for the original finding. However, since CSLFRF funds were also received increasing the County’s funding in excess of $100 million the annual chargeback plans were submitted to the cognizant agency and U.S. Treasury in 2023 for implementation in FY 24 and will continue to submit subsequent plans to federal cognizant agency, as required by 2 CFR 200 Appendix V.

Categories

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs Material Weakness

Other Findings in this Audit

  • 394712 2023-010
    Material Weakness
  • 394713 2023-011
    Significant Deficiency
  • 394714 2023-012
    Material Weakness
  • 394715 2023-012
    Material Weakness
  • 394716 2023-012
    Material Weakness
  • 394717 2023-012
    Material Weakness
  • 394718 2023-012
    Material Weakness
  • 394719 2023-012
    Material Weakness
  • 394720 2023-012
    Material Weakness
  • 394721 2023-012
    Material Weakness
  • 394722 2023-012
    Material Weakness
  • 394723 2023-012
    Material Weakness
  • 394724 2023-012
    Material Weakness
  • 394725 2023-012
    Material Weakness
  • 394726 2023-012
    Material Weakness
  • 394727 2023-012
    Material Weakness
  • 394728 2023-013
    Material Weakness
  • 394729 2023-014
    Material Weakness Repeat
  • 394730 2023-014
    Material Weakness Repeat
  • 394731 2023-015
    Material Weakness Repeat
  • 394732 2023-015
    Material Weakness Repeat
  • 394733 2023-015
    Material Weakness Repeat
  • 394734 2023-015
    Material Weakness Repeat
  • 394736 2023-015
    Material Weakness Repeat
  • 394737 2023-015
    Material Weakness Repeat
  • 394738 2023-015
    Material Weakness Repeat
  • 394739 2023-016
    Significant Deficiency
  • 394740 2023-016
    Significant Deficiency
  • 394741 2023-016
    Significant Deficiency
  • 394742 2023-016
    Significant Deficiency
  • 394743 2023-016
    Significant Deficiency
  • 394744 2023-016
    Significant Deficiency
  • 394745 2023-016
    Significant Deficiency
  • 394746 2023-016
    Significant Deficiency
  • 394747 2023-017
    Significant Deficiency
  • 971154 2023-010
    Material Weakness
  • 971155 2023-011
    Significant Deficiency
  • 971156 2023-012
    Material Weakness
  • 971157 2023-012
    Material Weakness
  • 971158 2023-012
    Material Weakness
  • 971159 2023-012
    Material Weakness
  • 971160 2023-012
    Material Weakness
  • 971161 2023-012
    Material Weakness
  • 971162 2023-012
    Material Weakness
  • 971163 2023-012
    Material Weakness
  • 971164 2023-012
    Material Weakness
  • 971165 2023-012
    Material Weakness
  • 971166 2023-012
    Material Weakness
  • 971167 2023-012
    Material Weakness
  • 971168 2023-012
    Material Weakness
  • 971169 2023-012
    Material Weakness
  • 971170 2023-013
    Material Weakness
  • 971171 2023-014
    Material Weakness Repeat
  • 971172 2023-014
    Material Weakness Repeat
  • 971173 2023-015
    Material Weakness Repeat
  • 971174 2023-015
    Material Weakness Repeat
  • 971175 2023-015
    Material Weakness Repeat
  • 971176 2023-015
    Material Weakness Repeat
  • 971177 2023-015
    Material Weakness Repeat
  • 971178 2023-015
    Material Weakness Repeat
  • 971179 2023-015
    Material Weakness Repeat
  • 971180 2023-015
    Material Weakness Repeat
  • 971181 2023-016
    Significant Deficiency
  • 971182 2023-016
    Significant Deficiency
  • 971183 2023-016
    Significant Deficiency
  • 971184 2023-016
    Significant Deficiency
  • 971185 2023-016
    Significant Deficiency
  • 971186 2023-016
    Significant Deficiency
  • 971187 2023-016
    Significant Deficiency
  • 971188 2023-016
    Significant Deficiency
  • 971189 2023-017
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 - Emergency Rental Assistance Program $13.81M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.77M
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $1.81M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.42M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.41M
14.231 Covid-19 - Emergency Solutions Grant Program $1.14M
66.469 Great Lakes Program $1.01M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $957,000
93.137 Covid-19 - Community Programs to Improve Minority Health Grant Program $947,779
14.228 Covid-19 - Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $862,345
93.268 Covid-19 - Immunization Cooperative Agreements $843,398
16.575 Crime Victim Assistance $834,082
93.658 Foster Care_title IV-E $741,000
93.053 Nutrition Services Incentive Program $654,605
93.563 Child Support Enforcement $648,004
14.218 Community Development Block Grants/entitlement Grants $508,760
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $503,426
93.224 Covid-19 - Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $374,516
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $332,125
93.268 Immunization Cooperative Agreements $321,880
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $306,867
16.588 Violence Against Women Formula Grants $275,834
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $261,069
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $239,291
14.231 Emergency Solutions Grant Program $235,226
93.767 Children's Health Insurance Program $234,037
16.606 State Criminal Alien Assistance Program $184,035
93.889 National Bioterrorism Hospital Preparedness Program $145,701
93.940 Hiv Prevention Activities_health Department Based $144,819
20.205 Highway Planning and Construction $140,613
16.585 Drug Court Discretionary Grant Program $131,223
97.012 Boating Safety Financial Assistance $129,200
16.710 Public Safety Partnership and Community Policing Grants $128,323
97.067 Homeland Security Grant Program $80,844
97.042 Emergency Management Performance Grants $62,952
93.069 Public Health Emergency Preparedness $59,381
16.738 Edward Byrne Memorial Justice Assistance Grant Program $53,010
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $49,496
14.239 Covid-19 - Home Investment Partnerships Program $32,655
16.833 National Sexual Assault Kit Initiative $27,915
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $26,720
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $24,242
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $23,997
14.239 Home Investment Partnerships Program $21,419
93.472 Title IV-E Prevention and Family Services and Programs (a) $19,458
16.554 National Criminal History Improvement Program (nchip) $18,695
93.778 Medical Assistance Program $16,670
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $14,383
93.870 Covid-19 - Maternal, Infant and Early Childhood Home Visiting Grant $9,907
95.001 High Intensity Drug Trafficking Areas Program $8,232
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $7,764
93.994 Maternal and Child Health Services Block Grant to the States $239
66.468 Capitalization Grants for Drinking Water State Revolving Funds $231