THE WOMEN'S CENTER

2025-003 – INTERNAL CONTROLS OVER PAYROLL AND BENEFITS ALLOCATIONS Federal Agency: U.S. Department of Justice Federal Program: Victim of Crimes Act (VOCA) Assistance Listing Number(s): 16.575 Pass-through Agency: Michigan Department of Health and Human Services Grant Number(s): E20252997, E20254232, and E20252320 Condition: The Organization utilized PARs to allocate employee time between programs. During the payroll testing some minor variances were noted between the hours reported on the PARs and the hours recorded in the payroll system. Additionally, some minor variances were noted in charges for benefits compared to supporting documents. Criteria: Organizations must have proper internal control over allocations regarding salaries and wages and fringe benefits. In addition, allocations must be based on records that accurately reflect the work performed. It is the Organization’s procedure to utilize personnel activity reports (PARs) for its records to accurately reflect the work performed. Cause: Due to limited staffing, the Organization does not have a procedure in place to review manual inputs into the accounting system. Effect: The Organization did not follow proper internal controls due to reported hours having minor differences compared to actual timesheets and fringe benefits not matching supporting documentation. Questioned Costs: Not applicable. Perspective: Of the sixty (60) transactions selected for review, twelve (12) had errors in total hours, hours allocations, or benefit allocations. Repeat Finding: No. Recommendation: The Organization should have a review process to ensure the payroll system matches the PARs and benefits match the supporting documents. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.

2025-004 – COMPLIANCE AND CONTROLS OVER REPORTING Federal Agency: U.S. Department of Justice Federal Program: Victim of Crimes Act (VOCA) Assistance Listing Number(s): 16.575 Pass-through Agency: Michigan Department of Health and Human Services Grant Number(s): E20252997, E20254232, and E20252320 Condition: The Organization does have a reporting calendar to ensure all reports are completed and filed by the specified due dates. However, due to staff turnover, the calendar was not properly utilized by staff. As a result, the Michigan Department of Health and Human Services Fiscal Questionnaire was filed late. Criteria: The Organization is required to file numerous reports in relation to its grants, including but not limited to Financial Status Reports, Work Progress Reports, and Fiscal Questionnaires. In addition, all these reports have specific due dates that need to be followed. Cause: The Organization does have a process for identifying and tracking reporting deadlines for its grants. However, due to turnover in the Finance Director position this was not properly communicated. As a result, the incoming Finance Director was not aware of all applicable reporting requirements and due dates. Effect: The Organization did not file the Michigan Department of Health and Human Services Fiscal Questionnaire until informed by the pass-through agency that the report was past due. Until procedures are updated and communicated, the Organization may miss other reporting deadlines in the future. Questioned Costs: Not applicable. Perspective: The Michigan Department of Health and Human Services Fiscal Questionnaire was only completed after the pass-through agency made the Organization aware of the requirement. Repeat Finding: No. Recommendation: The Organization should update procedures to ensure timely compliance with grant reporting requirements. These procedures should include communicating and maintaining a reporting calendar that identifies all required reports and their respective due dates. Grant-related documents should be maintained in a centralized location to support consistent access, oversight, and monitoring of reporting obligations. To facilitate timely completion and review, the reporting calendar should include internal deadlines established in advance of external due dates, typically ranging from three days to two weeks. These internal deadlines would help reduce last-minute revisions and allow sufficient time for final review and approval prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.

2021-002 TRACKING OF EMPLOYEE GRANT RELATED ACTIVITIES (REPEAT) Federal Agency(ies): U.S. Department of Justice; U.S. Department of Health and Human Services Federal Program(s): Crime Victim Assistance (VOCA); Temporary Assistance for Needy Families; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services ALN(s): 16.575; 93.558; 93.671 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E20211601; E20211779; E20211780; E20211600; E20212522; E20211722 Criteria: The grant agreement with the Michigan Department of Health and Human Services (MDHHS) requires compliance with federal and state laws, guidelines, rules, and regulations. Title 2 CFR 200.430(1) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Also, the grant agreement with MDHHS requires hourly timesheets describing work activity, signed by the employee and supervisor, to document hours personnel worked on grant related activities. Condition: During an MDHHS audit of the Crime Victim and Domestic Violence programs dated November 18, 2021, it was noted that the Organization did not sufficiently track its employees? actual activity performed. Of the employees selected for testing, the Organization had hourly timesheets signed by the employee and supervisor; however, the timesheets did not provide sufficient detail of the actual activity(ies) performed to support payroll costs charged to the program. Cause: The Organization did not fully understand the requirements of 2 CFR 200 and the grant agreement in regard to documentation of compensation for work performed related to grant activities. Effect: The Organization?s the timesheets did not provide sufficient detail of the actual activity performed to support payroll costs charged to the grant program. Questioned Cost(s): None. Perspective: Two (29%) of the seven employees selected for testing had timesheets that lacked sufficient detail of the actual activity performed to support the payroll costs that were charged to the federal program. Repeat Finding: Yes; prior year finding 2020-002. Recommendation: The Organization should implement an internal control system to ensure that employees? time sheets include the actual activity performed to ensure compliance with federal and state laws, guidelines, rules, and regulations. Furthermore, as part of its internal control system the Organization should implement a managerial review procedure for payroll expenditures to determine allowability in relation to the grant and reconcile allowable costs to budgeted expenditure areas so that, as applicable, proper adjustments can be made. Managements Response: See separate Corrective Action Plan.

2021-003 AUTHORIZATION PRIOR TO PAYMENT (REPEAT) Federal Agency(ies): U.S. Department of Justice; U.S. Department of Health and Human Services Federal Program(s): Crime Victim Assistance (VOCA); Temporary Assistance for Needy Families ALN(s): 16.575; 93.558 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E20211601 Criteria: Title 2 CFR 200.302(b) requires that the financial management system of each non-Federal entity must provide records that contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. The Organization?s Accounting Manual also states that purchases between $200 and $750 are to be authorized by the Finance Manager. Purchases over $750 must be authorized by the Executive Director. Purchases under $200 can be authorized by the Office Coordinator to ensure the smooth running of the Organization?s programs. Condition: The Organization did not obtain management authorization on invoices prior to payment. Cause: The Organization has experienced some turnover of staffing in recent years. Additionally, the COVID-19 pandemic has at times made it difficult to maintain the Organization?s operations as previously performed. Effect: The Organization was not in compliance with Federal regulations and was not following its own procurement policies and procedures. Questioned Cost(s): None. Perspective: During an MDHHS audit of the Crime Victim and Domestic Violence programs dated November 18, 2021, it was noted that 12 (92%) of 13 sampled items for the CVA, SACS, SAVS, and TSH Programs for fiscal year 2020 did not have any authorization. Repeat Finding: Yes; prior year finding 2020-003. Recommendation: The Organization should implement an internal control system to ensure proper management authorization on all its invoices prior to payment to ensure compliance with Federal regulation and its own policies and procedures. Part of the internal control system should be communication with responsible staff about the requirements of 2 CFR 200.302(b) and its own procurement policies and procedures. Managements Response: See separate Corrective Action Plan.

2021-004 TRAVEL REIMBURSEMENTS (REPEAT) Federal Agency(ies): U.S. Department of Justice Federal Program(s): Crime Victim Assistance (VOCA) ALN(s): 16.575 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E2011601; E20211722; E20211600 Criteria: In accordance with the grant agreement travel reimbursement is an allowable expenditure and is to be based on the entity?s documented reimbursement rate. If the entity does not have a documented reimbursement rate then the State of Michigan?s travel reimbursement rate is utilized. The Organization?s Travel Expense Reimbursement policy specifies that the Organization uses the federally approved milage rate for business use of personal vehicles. Additionally, in accordance with the policy, summaries of the reimbursement request (Travel Expense Vouchers) are to be submitted to the Finance Manager within 30 days of when the travel was completed. Condition: The Organization reimbursed employees at the 2016 IRS Mileage rate of 54 cents per mile rather than the 2020 IRS Mileage rate of 57.5 cents per mile or 2021 IRS Mileage rate of 56.0 cents per mile as applicable. Two of the Travel Expense Vouchers selected for testing were for periods beyond 30 days of when the travel was completed. Cause: The Organization?s Travel Expense Voucher is erroneously generating the reimbursement amounts based on the 2016 IRS Mileage Rate of 54 cents per mile for business use. A breakdown of the Organization?s internal control system resulted in the error going undetected for the entire fiscal year and perhaps beyond. Effect: The Organization was not following its own Travel Expense Reimbursement policy and employees were reimbursed at a rate less than the IRS Mileage Rate. If a Travel Expense Voucher is not completed and submitted timely it may result in misstatements of the amounts due to error or fraud that may go undetected by management. Questioned Cost(s): None. Perspective: Three months of travel reimbursements were selected for recalculation which amounted to a total of twenty-four (24) travel expense vouchers that were reviewed. Of the 24 vouchers or 100% of them were calculated incorrectly. The total difference between the correct amount and the amount actually paid for the transactions was less than $100. Two of the seventeen travel expense vouchers were submitted more than 30 days after the travel was completed: 1) reimbursement for the month of March 2021 was submitted in June 2021; and 2) reimbursement for the month of April 2021 was submitted in June 2021. Repeat Finding: Yes; prior year finding 2020-004. Recommendation: The Organization should implement an internal control system to ensure that the Travel Expense Voucher is setup utilizing the appropriate IRS Mileage Rate for the period(s) covered. This system should take into account that due to the fact that the Organization has a September year end that there is a high probability that two reimbursement rates will be utilized during the year as the IRS Mileage Rate is released in January each year. To ensure that the Travel Expense Vouchers are submitted to the Finance Manager within 30 days of the completed travel it is recommended that submission process be more formalized and that it is done with some other routine procedures such as submitting it bi-weekly as part of payroll. Managements Response: See separate Corrective Action Plan.

Federal Agency(ies): U.S. Department of Justice; U.S. Department of Health and Human Services Federal Program(s): Crime Victim Assistance (VOCA); Temporary Assistance for Needy Families; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services CFDA(s): 16.575; 93.558; 93.671 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E20202047; E20201970; E20203271; E20202548; E20202547; E20203561 Criteria: The grant agreement with the Michigan Department of Health and Human Services (MDHHS) requires compliance with federal and state laws, guidelines, rules, and regulations. Title 2 CFR 200.430(1) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Also, the grant agreement with MDHHS requires hourly timesheets describing work activity, signed by the employee and supervisor, to document hours personnel worked on grant related activities. Condition: During an MDHHS audit of the Crime Victim and Domestic Violence programs dated November 18, 2021, it was noted that the Organization did not sufficiently track its employees? actual activity performed. Of the employees selected for testing, the Organization had hourly timesheets signed by the employee and supervisor; however, the timesheets did not provide sufficient detail of the actual activity(ies) performed to support payroll costs charged to the program. Cause: The Organization did not fully understand the requirements of 2 CFR 200 and the grant agreement in regard to documentation of compensation for work performed related to grant activities. Effect: The Organization?s the timesheets did not provide sufficient detail of the actual activity performed to support payroll costs charged to the grant program. Questioned Cost(s): None. Perspective: Three (50%) of the six employees selected for testing had timesheets that lacked sufficient detail of the actual activity performed to support the payroll costs that were charged to the federal program. Repeat Finding: No. Recommendation: The Organization should implement an internal control system to ensure that employees? time sheets include the actual activity performed to ensure compliance with federal and state laws, guidelines, rules, and regulations. Furthermore, as part of its internal control system the Organization should implement a managerial review procedure for payroll expenditures to determine allowability in relation to the grant and reconcile allowable costs to budgeted expenditure areas so that, as applicable, proper adjustments can be made. Managements Response: See separate Corrective Action Plan.

Federal Agency(ies): U.S. Department of Justice; U.S. Department of Health and Human Services Federal Program(s): Crime Victim Assistance (VOCA); Temporary Assistance for Needy Families CFDA(s): 16.575; 93.558 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E20202047; E20201970; E20203271; E20203561 Criteria: Title 2 CFR 200.302(b) requires that the financial management system of each non-Federal entity must provide records that contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation. The Organization?s Accounting Manual also states that purchases between $200 and $750 are to be authorized by the Finance Manager. Purchases over $750 must be authorized by the Executive Director. Purchases under $200 can be authorized by the Office Coordinator to ensure the smooth running of the Organization?s programs. Condition: The Organization did not obtain management authorization on invoices prior to payment. Cause: The Organization has experienced some turnover of staffing in recent years. Additionally, the COVID-19 pandemic has at times made it difficult to maintain the Organization?s operations as previously performed. Effect: The Organization was not in compliance with Federal regulations and was not following its own procurement policies and procedures. Questioned Cost(s): None. Perspective: During an MDHHS audit of the Crime Victim and Domestic Violence programs dated November 18, 2021, it was noted that 12 (92%) of 13 sampled items for the CVA, SACS, SAVS, and TSH Programs for fiscal year 2020 did not have any authorization. Repeat Finding: No. Recommendation: The Organization should implement an internal control system to ensure proper management authorization on all its invoices prior to payment to ensure compliance with Federal regulation and its own policies and procedures. Part of the internal control system should be communication with responsible staff about the requirements of 2 CFR 200.302(b) and its own procurement policies and procedures. Managements Response: See separate Corrective Action Plan.

Federal Agency(ies): U.S. Department of Justice Federal Program(s): Crime Victim Assistance (VOCA) CFDA(s): 16.575 Pass-through Agency(ies): Michigan Department of Health and Human Services Grant Number(s): E20202047; E20201970 Criteria: In accordance with the grant agreement travel reimbursement is an allowable expenditure and is to be based on the entity?s documented reimbursement rate. If the entity does not have a documented reimbursement rate then the State of Michigan?s travel reimbursement rate is utilized. The Organization?s Travel Expense Reimbursement policy specifies that the Organization uses the federally approved milage rate for business use of personal vehicles. Additionally, in accordance with the policy, summaries of the reimbursement request (Travel Expense Vouchers) are to be submitted to the Finance Manager within 30 days of when the travel was completed. Condition: The Organization reimbursed employees at the 2016 IRS Mileage rate of 54 cents per mile rather than the 2019 IRS Mileage rate of 58 cents per mile or 2020 IRS Mileage rate of 57.5 cents per mile as applicable. Four of the Travel Expense Vouchers selected for testing were for periods beyond 30 days of when the travel was completed. Cause: The Organization?s Travel Expense Voucher is erroneously generating the reimbursement amounts based on the 2016 IRS Mileage Rate of 54 cents per mile for business use. A breakdown of the Organization?s internal control system resulted in the error going undetected for the entire fiscal year and perhaps beyond. Effect: The Organization was not following its own Travel Expense Reimbursement policy and employees were reimbursed at a rate less than the IRS Mileage Rate. If a Travel Expense Voucher is not completed and submitted timely it may result in misstatements of the amounts due to error or fraud that may go undetected by management. Questioned Cost(s): None. Perspective: Three months of travel reimbursements were selected for recalculation which amounted to a total of seventeen (17) travel expense vouchers that were reviewed. Of the 17 vouchers 100% of them were calculated incorrectly. The total difference between the correct amount and the amount actually paid for the transactions was less than $100. Four of the seventeen travel expense vouchers were submitted more than 30 days after the travel was completed: 1) reimbursement for the month of February 2020 was submitted in September 2020; 2) reimbursement for the months of May, June, July, and August 2020 was submitted in September 2020; 3) reimbursement for the months of February, June, July, and August 2020 was submitted in September 2020; and 4) reimbursement for the month of January 2020 was submitted in September 2020. Repeat Finding: No. Recommendation: The Organization should implement an internal control system to ensure that the Travel Expense Voucher is setup utilizing the appropriate IRS Mileage Rate for the period(s) covered. This system should take into account that due to the fact that the Organization has a September year end that there is a high probability that two reimbursement rates will be utilized during the year as the IRS Mileage Rate is released in January each year. To ensure that the Travel Expense Vouchers are submitted to the Finance Manager within 30 days of the completed travel it is recommended that submission process be more formalized and that it is done with some other routine procedures such as submitting it bi-weekly as part of payroll. Managements Response: See separate Corrective Action Plan.