EIN: 381802280
UEI: GSA_MIGRATION
Audited by: WIPFLI LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 29, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 29, 2021 (1887 days ago).
What is a management decision? →Finding 2019-001: Internal Control Over Financial Reporting Condition Several deficiencies were identified related to Muskegon-Oceana Community Action Partnership, Inc.?s (MOCAP) internal control over financial reporting. This is a repeat of the original audit finding 2017-001. MOCAP implemented changes to address the matters identified in 2017-001, however other items were identfied for the year ended September 30, 2019. The matters identified are as follows: ? MOCAP experienced a complete loss of all electronic data during the year ended September 30, 2019 as a result of a ransomware attack. While MOCAP does have paper supporting back up to assist with rebuilding its accounting database, the lack of sufficient backup systems to recover from the ransomware attack is a material weakness in internal control over financial reporting. ? Audit adjustments were proposed and accepted by management to cash, accounts payable and grants receivable balances. Some of the adjustments were the result of accounts not reconciled from the ransomware attack. Criteria Uniform Guidance 200.302(b)(4) states each non-federal entity must provide for ?effective control over, and accountability for, all funds, property, and other assets.? Cause The lack of a viable backup resulted in a complete loss of data, reconstruction of the data was time consuming. Furthermore, reimbursements from the State of Michigan were suspended/delayed causing staff reductions which reduced the time available for account reconciliations and data reconstruction. Effect A material weakness in internal control over financial reporting exists due to the above deficiencies in internal control over financial reporting. Recommendation We recommend that MOCAP implement systems and procedures to ensure internal controls over financial reporting are improved. View of Responsible Officials Management agrees with the finding and has developed and begun implementation of a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-001: Internal Control Over Financial Reporting Condition Several deficiencies were identified related to Muskegon-Oceana Community Action Partnership, Inc.?s (MOCAP) internal control over financial reporting. This is a repeat of the original audit finding 2017-001. MOCAP implemented changes to address the matters identified in 2017-001, however other items were identfied for the year ended September 30, 2019. The matters identified are as follows: ? MOCAP experienced a complete loss of all electronic data during the year ended September 30, 2019 as a result of a ransomware attack. While MOCAP does have paper supporting back up to assist with rebuilding its accounting database, the lack of sufficient backup systems to recover from the ransomware attack is a material weakness in internal control over financial reporting. ? Audit adjustments were proposed and accepted by management to cash, accounts payable and grants receivable balances. Some of the adjustments were the result of accounts not reconciled from the ransomware attack. Criteria Uniform Guidance 200.302(b)(4) states each non-federal entity must provide for ?effective control over, and accountability for, all funds, property, and other assets.? Cause The lack of a viable backup resulted in a complete loss of data, reconstruction of the data was time consuming. Furthermore, reimbursements from the State of Michigan were suspended/delayed causing staff reductions which reduced the time available for account reconciliations and data reconstruction. Effect A material weakness in internal control over financial reporting exists due to the above deficiencies in internal control over financial reporting. Recommendation We recommend that MOCAP implement systems and procedures to ensure internal controls over financial reporting are improved. View of Responsible Officials Management agrees with the finding and has developed and begun implementation of a corrective action plan.
Finding 2019-001: Internal Control Over Financial Reporting Management?s Response ? Due to the encryption of MOCAP?s data in February 2019, changes have been made to MOCAP?s systems that include additional virus protection, and an improved data backup system. Backup is done in-house continuously with a nightly Cloud upload. Backup had previously been done every other day on-site; centrally to protect the agency?s data from natural disasters. There is not an open connection between the server and the backup that can be exploited. ? New corrective protections over internal control over financial reporting and agency data include, but are not limited to: Document software and hardware changes, ongoing monthly reports of work accomplished, Monthly Monitoring Agents (Microsoft), ongoing check print queues, an as needed Business Application / ERP / Liaison, as needed SQL server management, off-time server maintenance, installed supported software upgrades, and more. ? A Forensic and legal review was done of the data breach, and it was determined that MOCAP?s data breach incident does not meet the threshold definitions of a security breach of personal information, and with such, that MOCAP is not legally required to notify any individuals, the media, or federal/state regulators of this incident. ? Journal Entries, Bank Reconciliations and Invoices continue to be approved, with consistency with MOCAP personnel, the Policies are more in the forefront. With consistent personnel there is more opportunity for check and recheck systems. Contact Person Responsible for Corrective Action: Arturo Puckerin, Executive Director Anticipated Completion Date: September 30, 2020
2018-001
Finding 2019-002: Cost Allocation Questioned Costs: None Grant Funding Source Grant Period Department of Heatlh and Human Services ? CFDA#93.569 Community Services Block Grant Michigan Department of Health 10/01/18-09/30/19 #CSBG-14-61021 and Human Services Community Services Block Grant - Michigan Department of Health 10/01/17-09/30/19 Carryover #CSBG-14-61021 and Human Services Condition In practice, MOCAP generally charges administrative salaries to the Community Services Block Grant (CSBG) program and then charges other grants depending on available funding rather than based on a cost allocation plan. Additionally, MOCAP did create a cost allocation plan for other non-personnel costs, however, the plan was not implemented and utilized during the year ended September 30, 2019. This is a repeat of the original audit finding 2017-004. Criteria Uniform Guidance 200.405(d) states ?Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Cause Management did not have the time or resources to implement a comprehensive cost allocation plan. Effect A significant deficiency in internal control over compliance exists due to not implementing a comprehensive written cost allocation plan. Section III ? Federal Award Findings and Questioned Costs (Continued) Recommendation We recommend that MOCAP implement the cost allocation plan in place for allocating administrative expenses to the programs. View of Responsible Officials Management agrees with the finding and has developed and begun implementation of a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-002: Cost Allocation Questioned Costs: None Grant Funding Source Grant Period Department of Heatlh and Human Services ? CFDA#93.569 Community Services Block Grant Michigan Department of Health 10/01/18-09/30/19 #CSBG-14-61021 and Human Services Community Services Block Grant - Michigan Department of Health 10/01/17-09/30/19 Carryover #CSBG-14-61021 and Human Services Condition In practice, MOCAP generally charges administrative salaries to the Community Services Block Grant (CSBG) program and then charges other grants depending on available funding rather than based on a cost allocation plan. Additionally, MOCAP did create a cost allocation plan for other non-personnel costs, however, the plan was not implemented and utilized during the year ended September 30, 2019. This is a repeat of the original audit finding 2017-004. Criteria Uniform Guidance 200.405(d) states ?Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Cause Management did not have the time or resources to implement a comprehensive cost allocation plan. Effect A significant deficiency in internal control over compliance exists due to not implementing a comprehensive written cost allocation plan. Section III ? Federal Award Findings and Questioned Costs (Continued) Recommendation We recommend that MOCAP implement the cost allocation plan in place for allocating administrative expenses to the programs. View of Responsible Officials Management agrees with the finding and has developed and begun implementation of a corrective action plan.
Finding 2019-002: Cost Allocation Management?s Response The February 2019 data breach impacted this system, but MOCAP does indeed have a Cost Allocation Policy and Plan, however, they were not completed until near the 2019 Fiscal Year end, in August of 2019. Contact Person Responsible for Corrective Action: Arturo Puckerin, Executive Director Anticipated Completion Date: September 30, 2020
2018-002
FAC accepted this audit on June 27, 2019 — management decision was due December 27, 2019.
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2017-001
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2017-004
FAC accepted this audit on June 28, 2018 — management decision was due December 28, 2018.
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2016-003
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FAC accepted this audit on August 14, 2017 — management decision was due February 14, 2018.
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Show full finding ▾Hide full finding ▴Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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