Finding 519115 (2024-003)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2024
Accepted
2025-01-14
Audit: 337640
Organization: City of Detroit, Michigan (MI)

AI Summary

  • Core Issue: The City failed to liquidate obligations within the required 60 days after the grant period, leading to a material weakness in compliance.
  • Impacted Requirements: The City did not adhere to the 60-day liquidation rule set by the Michigan Department of Health and Human Services, which is stricter than federal guidelines.
  • Recommended Follow-Up: Implement stronger controls to ensure timely liquidation of expenses and collaborate with the Health Department for improved invoice review processes.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 232MI013W5003 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2023-004 Criteria - Per 2 CFR 200.344(c), unless the federal awarding agency or pass through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(c), the City must liquidate within 60 days after the State's fiscal year end any unpaid year end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days from the end of the grant period and certain costs were liquidated after 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - There were two invoices totaling $251,332 that were not paid at the end of the grant period. A review of both invoices revealed that they were liquidated after the required 60 days for the performance period ended September 30, 2023. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60 day period. As a result, no questioned costs are reported. Cause and Effect - The controls in place were not effective to ensure grant expenditures were liquidated within 60 days following the end of the grant period. Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or the Uniform Guidance issued by OMB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The Office of the Chief Financial Officer (OCFO) is collaborating with the Health Department to implement enhanced processes over the final review of invoices to address timing related to the liquidation requirement.

Corrective Action Plan

Federal Program, Assistance Listing Number and Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days from the end of the grant period and certain costs were liquidated after 60 days. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Regina Greear, Terri Daniels, Denise Fair; Anticipated completion date: June 2025 Planned Corrective Action - The City has ongoing efforts to implement enhanced processes over the final review of invoices to address timing related to the liquidation requirement.

Categories

Period of Performance Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 519114 2024-002
    Significant Deficiency
  • 519116 2024-004
    Material Weakness
  • 519117 2024-004
    Material Weakness
  • 519118 2024-004
    Material Weakness
  • 519119 2024-005
    Material Weakness
  • 519120 2024-005
    Material Weakness
  • 519121 2024-005
    Material Weakness
  • 519122 2024-006
    Material Weakness
  • 519123 2024-006
    Material Weakness
  • 519124 2024-006
    Material Weakness
  • 1095556 2024-002
    Significant Deficiency
  • 1095557 2024-003
    Material Weakness Repeat
  • 1095558 2024-004
    Material Weakness
  • 1095559 2024-004
    Material Weakness
  • 1095560 2024-004
    Material Weakness
  • 1095561 2024-005
    Material Weakness
  • 1095562 2024-005
    Material Weakness
  • 1095563 2024-005
    Material Weakness
  • 1095564 2024-006
    Material Weakness
  • 1095565 2024-006
    Material Weakness
  • 1095566 2024-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $9.44M
93.914 Hiv Emergency Relief Project Grants $7.53M
14.239 Home Investment Partnerships Program $4.95M
14.241 Housing Opportunities for Persons with Aids $2.79M
93.686 Ending the Hiv Epidemic: A Plan for America Ryan White Hiv/aids Program Parts A and B $2.69M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $2.57M
14.231 Emergency Solutions Grant Program $2.53M
20.507 Federal Transit Formula Grants $2.24M
20.205 Highway Planning and Construction $1.98M
93.391 Covid-19 - Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.87M
14.920 Lead Hazard Control for High Risk Areas $1.55M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $1.35M
14.231 Covid-19 - Emergency Solutions Grant Program $1.32M
16.738 Edward Byrne Memorial Justice Assistance Grant Program $798,748
21.023 Covid-19 - Emergency Rental Assistance Program $789,995
14.850 Public Housing Operating Fund $743,306
93.994 Maternal and Child Health Services Block Grant to the States $674,038
10.559 Summer Food Service Program for Children $562,094
14.905 Lead Hazard Reduction Demonstration Grant Program $526,534
21.027 Cocid-19 Coronavirus State and Local Fiscal Recovery Funds $454,561
20.507 Covid-19 - Federal Transit Formula Grants $403,873
14.239 Covid-19 - Home Investment Partnerships Program $351,577
16.753 Congressionally Recommended Awards $343,438
16.807 Covid-19 Voca Crime Victim Assistance Discretionary Grant Program $339,780
20.106 Covid-19 - Airport Improvement Program, Covid-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs $316,666
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $266,516
93.767 Children's Health Insurance Program $234,136
93.917 Hiv Care Formula Grants $216,975
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $215,186
66.458 Clean Water State Revolving Fund $206,226
16.812 Second Chance Act Reentry Initiative $194,185
20.941 Strengthening Mobility and Revolutionizing Transportation (smart) Grants Program $193,332
15.929 Save America's Treasures $177,253
93.268 Covid-19 - Immunization Cooperative Agreements $158,747
20.616 National Priority Safety Programs $126,829
93.069 Public Health Emergency Preparedness $125,541
16.817 Byrne Criminal Justice Innovation Program $125,058
16.609 Project Safe Neighborhoods $116,170
15.904 Historic Preservation Fund Grants-in-Aid $111,505
16.575 Crime Victim Assistance $105,122
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $102,697
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $85,571
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $83,212
14.218 Covid-19 Community Development Block Grants/entitlement Grants $82,184
93.136 Covid-19 - Injury Prevention and Control Research and State and Community Based Programs $60,230
16.710 Public Safety Partnership and Community Policing Grants $59,842
14.900 Lead Hazard Reduction Grant Program $58,103
93.940 Hiv Prevention Activities Health Department Based $50,783
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $38,618
93.778 Medical Assistance Program $34,101
93.217 Family Planning Services $30,672
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $27,832
93.361 Covid-19 - Nursing Research $26,641
97.067 Homeland Security Grant Program $26,514
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $25,881
45.024 Promotion of the Arts Grants to Organizations and Individuals $24,761
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $23,992
14.218 Community Development Block Grants/entitlement Grants $19,479
16.588 Violence Against Women Formula Grants $18,538
97.044 Assistance to Firefighters Grant $18,435
20.500 Federal Transit Capital Investment Grants $13,891
97.042 Emergency Management Performance Grants $11,669
16.036 Comprehensive Forensic Dna Analysis Grant Program $5,764
93.268 Immunization Cooperative Agreements $5,645
93.008 Medical Reserve Corps Small Grant Program $5,132
20.600 State and Community Highway Safety $4,698
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4,341
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $4,196
10.558 Child and Adult Care Food Program $1,720
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs $1,544