Finding Text
2022-007 – Written Policies Required by the Uniform Guidance (repeat
Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and
Allowable Costs/Cost Principles)
Federal Program: U.S. Department of Transportation – Airport Improvement Program (AL
#20.106); all project numbers and U.S. Department of Treasury – Coronavirus State and Local
Fiscal Recovery Funds (AL #21.027)
Criteria: Delta County does not have written policies and procedures to implement the
requirements of 2 CFR section 200 for the administration of federal awards specific to the Airport
or for federal awards in general. The Uniform Guidance requires a non-federal entity that has
expended federal awards for a grant on or after December 26, 2014 to have written policies
pertaining to: 1) advance payments and reimbursements; 2) determination of allowable costs; 3)
compensation (personnel and benefits policies); 4) travel costs; and 5) procurement procedures. 2
CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls
over the federal awards that provide assurance that the entity is managing the federal awards in
compliance with federal statutes, regulations, and the conditions of the federal award.
Condition: The County does not have processes in place to conform to all of the requirements in
the Uniform Guidance. There are no formal written policies in place specifically related to the
Airport. Additionally, the Airport does not have a clear determination of the assignment of
responsibilities between Airport management, Michigan Department of Transportation (the State)
and other consultants.
Cause: The County has not reviewed and updated its policies and procedures for continued
changes in grants and the Uniform Guidance. The Airport grants operate outside of the general
County processes and internal control system given the administration assistance provided by the
State and other consultants. Also, Airport management has experienced significant turnover.
Effect: As a result of this condition, the County did not fully comply with the Uniform Guidance.
Questioned Costs: No costs have been questioned as a result of this finding.
Recommendation: We recommend that the County and the Airport adopt formal written policies
covering these areas as soon as practical. The Airport should also formalize responsibilities with
the State and other consultants.
Views of Responsible Officials: The County will work to update policies and procedures and to
formalize responsibilities.