Finding 84346 (2022-003)

2022-003 ? Written Policies Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency In Internal Controls Over Compliance (Allowable Costs/Cost Principles and Cash Management) Federal program: Pass-through Lucas County Job and Family Services COVID-19 - Temporary Assistance for Needy Families (CFDA #93.558); U.S. Department of Health and Human Services Criteria. The Uniform Grant 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 elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (?200.302 (6)); 2) Allowability of costs charged to federal programs (?200.302 (7)); and 3) Compensation (personnel and benefits policy) (?200.430 and ?200.431). Condition. Although the Organization has processes in place to cover these areas, there are no formal written policies for payments and allowability of costs charged to federal programs. Cause. This condition appears to be the result of an oversight 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 Grant Guidance applicable to its federal programs. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. Formal written policies should be prepared to comply with the Uniform Guidance. View of Responsible Officials. Management agrees with this finding and has prepared a corrective action plan.