FAC Explorer

Finding 516550 (2024-005)

Significant Deficiency
Requirement
BC
Questioned Costs
-
Year
2024
Accepted
2024-12-23
Audit: 334487
Organization: United Way of the Battle Creek and Kalamazoo Region (MI)
Auditor: Rehmann Robson LLC

AI Summary

  • Core Issue: The organization lacks required written policies for key areas like payments, procurement, and travel costs, leading to significant internal control deficiencies.
  • Impacted Requirements: This noncompliance affects adherence to the Uniform Guidance, specifically sections related to federal fund management and cost principles.
  • Recommended Follow-Up: Implement written policies for all required areas to ensure compliance and improve internal controls; management has acknowledged this and is working on a Corrective Action Plan.

Finding Text

2024-005 – Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award 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 various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Auditor Description of Condition and Effect. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs, leading to noncompliance with Uniform Guidance. Auditor Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. Corrective Action. Management will develop and formalize written policies covering payments, procurement, allowability of costs, compensation, and travel costs. These policies will clearly outline procedures and approval processes to ensure compliance with Uniform Guidance. They will address key areas such as payment processing, procurement protocols, criteria for allowable costs on federal programs, compensation guidelines, and travel reimbursement rules, ensuring consistency and adherence to federal regulations. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. March 31, 2025

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 516540 2024-003
    Significant Deficiency
  • 516541 2024-003
    Significant Deficiency
  • 516542 2024-003
    Significant Deficiency
  • 516543 2024-003
    Significant Deficiency
  • 516544 2024-003
    Significant Deficiency
  • 516545 2024-004
    Significant Deficiency
  • 516546 2024-004
    Significant Deficiency
  • 516547 2024-004
    Significant Deficiency
  • 516548 2024-004
    Significant Deficiency
  • 516549 2024-004
    Significant Deficiency
  • 516551 2024-005
    Significant Deficiency
  • 516552 2024-005
    Significant Deficiency
  • 516553 2024-005
    Significant Deficiency
  • 516554 2024-005
    Significant Deficiency
  • 516555 2024-006
    Significant Deficiency
  • 516556 2024-006
    Significant Deficiency
  • 516557 2024-006
    Significant Deficiency
  • 516558 2024-006
    Significant Deficiency
  • 516559 2024-006
    Significant Deficiency
  • 1092982 2024-003
    Significant Deficiency
  • 1092983 2024-003
    Significant Deficiency
  • 1092984 2024-003
    Significant Deficiency
  • 1092985 2024-003
    Significant Deficiency
  • 1092986 2024-003
    Significant Deficiency
  • 1092987 2024-004
    Significant Deficiency
  • 1092988 2024-004
    Significant Deficiency
  • 1092989 2024-004
    Significant Deficiency
  • 1092990 2024-004
    Significant Deficiency
  • 1092991 2024-004
    Significant Deficiency
  • 1092992 2024-005
    Significant Deficiency
  • 1092993 2024-005
    Significant Deficiency
  • 1092994 2024-005
    Significant Deficiency
  • 1092995 2024-005
    Significant Deficiency
  • 1092996 2024-005
    Significant Deficiency
  • 1092997 2024-006
    Significant Deficiency
  • 1092998 2024-006
    Significant Deficiency
  • 1092999 2024-006
    Significant Deficiency
  • 1093000 2024-006
    Significant Deficiency
  • 1093001 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $430,515
55.059 United for Alice at Work $134,030
93.568 Low-Income Home Energy Assistance $79,625
14.267 Continuum of Care Program $50,127
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $27,246