Finding 522000 (2024-001)

Significant Deficiency
Requirement
BCI
Questioned Costs
-
Year
2024
Accepted
2025-02-04
Audit: 341240
Organization: Battle Creek Unlimited, Inc. (MI)

AI Summary

  • Core Issue: The Organization lacks formal written policies required by the Uniform Grant Guidance for federal grants.
  • Impacted Requirements: Key areas include payments, procurement, allowability of costs, compensation, and travel costs.
  • Recommended Follow-Up: Develop and implement the necessary policies promptly to ensure compliance.

Finding Text

2024-001 - Written Policies Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles, Cash Management, Procurement). Federal program(s) U.S. Department of Treasury -  COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) (ALN 21.027); Passed through Michigan Strategic Fund and Southwest Michigan First Corporation; All project 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: 1) Payments (draws of federal funds and how to minimize the time lapsing 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. Although the Organization has processes in place to cover these areas, there are no formal written policies covering payments, procurement, allowability of costs, compensation, and travel costs in accordance with the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were questioned as a result of this finding. Recommendation. We recommend that the Organization develop and implement the required policies as soon as practical. View of Responsible Officials. Management is in agreement and has prepared a Corrective Action Plan.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 521999 2024-001
    Significant Deficiency
  • 522001 2024-002
    Significant Deficiency
  • 522002 2024-003
    Significant Deficiency
  • 522003 2024-003
    Significant Deficiency
  • 1098441 2024-001
    Significant Deficiency
  • 1098442 2024-001
    Significant Deficiency
  • 1098443 2024-002
    Significant Deficiency
  • 1098444 2024-003
    Significant Deficiency
  • 1098445 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.024 Build to Scale $157,046
21.027 Coronavirus State and Local Fiscal Recovery Funds $51,177