Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 21.027, US Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Pass through Entity - Michigan Department of Health and Human Services (MDHHS)
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2023-001
Criteria - The Organization should have internal controls in place to ensure subrecipient agreements are executed prior to distribution of funds to a subrecipient to ensure proper compliance with the requirements of 2 CFR 200 and as a condition of the grant agreement with MDHHS.
Additionally, uniform grant guidance requires a pass through entity to conduct a formal risk assessment of subrecipient candidates prior to the commencement of a subrecipient relationship.
Condition - The Organization has engaged a subrecipient as part of this grant program, which was subsequently determined, but did not have an executed agreement with the subrecipient until October 2024. As a result, the Organization did not meet the requirements of performing formal risk assessment procedures prior to engaging with the subrecipient.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The Organization identified the subrecipient in the grant application submitted to MDHHS; however, at the time of the grant application submission, the relationship with the subrecipient was not fully determined. A subsequent evaluation of the relationship revealed that the subrecipient met the requirements as a subrecipient, and, therefore, the Organization failed to timely execute a formal subrecipient award agreement or conduct a formal risk assessment, as required of identified subrecipients. While the Organization has continued to maintain informal process to monitor the subrecipient for costs being charged to the grant, the Organization did not execute a formal subrecipient agreement in place until October 2024.
Cause and Effect - The Organization did not have controls in place to ensure these criteria were met. In addition to noncompliance with 2 CFR 200 and the terms and conditions of the grant agreement, the monthly financial status reports (FSRs) being filed monthly with MDHHS did not denote any subrecipient dollars being passed through to another entity until a correction was retroactively made in September 2024, and was then reported correctly going forward.
Recommendation - The Organization should execute a subrecipient agreement that is in accordance with 2 CFR 200.
Views of Responsible Officials and Corrective Action Plan - Management has executed an agreement with the identified subrecipient and implement formalized policies and procedures to ensure no risk factors for non compliance exist and to properly monitor the subrecipient activity. The identified subrecipient has met all documentation and submission requirements to support reporting and appropriate usage of grant funds related to the grant program.