Finding Text
Federal Aid Policies Finding 2023-002
Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred.
Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference.
a. Cash Management Procedure –200.302(b)(6) and 200.305
b. Cost Allowability Procedures –200.302(b)(7)
c. Conflicts of Interest Policy –200.318(c)
d. Procurement Procedures –200.318(a) and 200.319(d)
e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii)
f. Travel Policy –200.475(a)
g. Procedures for Managing Equipment –200.313(d)
h. Employee Benefits –200.431
Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption.
Effect: The Authority is noncompliant with 2 CFR 200.
Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200.
Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268.
The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.