EIN: 386004628
UEI: VARBEGGYV751
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 8, 2022. 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 September 8, 2022 (1445 days ago).
What is a management decision? →Multiple disbursements were not made within the required 30 days from receiving request for reimbursement from subrecipients. Criteria: The City must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. Cause: This condition appears to be the result of a greater amount of time required for approval of disbursements than the grant requirements allow based on effects of the COVID-19 global pandemic. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: The total amount of disbursements that were not disbursed within the required 30 days for the year ended June 30, 2021 was $171,528. Recommendation: We recommend that the City review its internal processes in relation to this requirement and modify procedures so as to comply with the obligation, expenditure, and payment requirements. View of Responsible Officials: The City agrees there is an obligation to pay subrecipients for allowable costs within 30 days after receiving their complete payment request. The 30 days applies to complete and accurate payment requests. Should the payment request not meet this criteria, current policy is to require submission of a revised request and the 30-day clock restarts upon its receipt. The pandemic also impacted City procedures during this grant period. Changing from weekly to bi-weekly check runs affected the frequency of payments, making the 30-day window more difficult to attain. Remote work, staff layoffs, and additional grants to manage also presented challenges in accomplishing more work with less time. To address this finding, the City will review and modify its internal procedures to streamline the movement of payments through the system in order to comply with the 30 day requirement.
Show full finding ▾Hide full finding ▴2021-008 OBLIGATION, EXPENDITURE, AND PAYMENT REQUIREMENTS Finding Type: Material Noncompliance/Material Weakness in Internal Control over Compliance (Special Test and Provisions). Programs: Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.231; All Award Numbers. Condition: Multiple disbursements were not made within the required 30 days from receiving request for reimbursement from subrecipients. Criteria: The City must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. Cause: This condition appears to be the result of a greater amount of time required for approval of disbursements than the grant requirements allow based on effects of the COVID-19 global pandemic. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: The total amount of disbursements that were not disbursed within the required 30 days for the year ended June 30, 2021 was $171,528. Recommendation: We recommend that the City review its internal processes in relation to this requirement and modify procedures so as to comply with the obligation, expenditure, and payment requirements. View of Responsible Officials: The City agrees there is an obligation to pay subrecipients for allowable costs within 30 days after receiving their complete payment request. The 30 days applies to complete and accurate payment requests. Should the payment request not meet this criteria, current policy is to require submission of a revised request and the 30-day clock restarts upon its receipt. The pandemic also impacted City procedures during this grant period. Changing from weekly to bi-weekly check runs affected the frequency of payments, making the 30-day window more difficult to attain. Remote work, staff layoffs, and additional grants to manage also presented challenges in accomplishing more work with less time. To address this finding, the City will review and modify its internal procedures to streamline the movement of payments through the system in order to comply with the 30 day requirement.
2021-008 OBLIGATION, EXPENDITURE, AND PAYMENT REQUIREMENTS Management Assessment: We concur with the audit assessment regarding this matter. Planned Corrective Action: The City agrees there is an obligation to pay subrecipients for allowable costs within 30 days after receiving their complete payment request. The 30 days applies to complete and accurate payment requests. Should the payment request not meet this criteria, current policy is to require submission of a revised request and the 30-day clock restarts upon its receipt. The pandemic also impacted City procedures during this grant period. Changing from weekly to bi-weekly check runs affected the frequency of payments, making the 30-day window more difficult to attain. Remote work, staff layoffs, and additional grants to manage also presented challenges in accomplishing more work with less time. To address this finding, the City will review and modify its internal procedures to streamline the movement of payments through the system in order to comply with the 30 day requirement. Responsible Party: Wymon Curry, Grant Accountant and Kim Coleman, HRCS Director Date of Planned Corrective Action: June 30, 2022
2020-011
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
The following issues were noted during grant compliance testing: COC & ESG Programs: The Human Resources and Community Services director and the director?s spouse were identified as being directors and/or on governing boards of subrecipient entities. Criteria: City policies, as well as clauses in external contracts and grant agreements, require reporting of any potential conflicts of interest related to payments to outside organizations for services provided to or on behalf of services provided by the City. Cause: The cause of this issue appears to be a lack of a process to test for relationships of this type when contracting with outside parties. Effect: As a result of this condition, the City HRCS Department was in violation of the City's internal conflict of interest policy, as well as conflict of interest clauses in the grant agreement related to the Continuum of Care and Emergency Solutions Grant programs. The fact that payments to these entities do not constitute an "arms length- transaction" causes the costs reported by these subrecipients to be in noncompliance with federal cost principles. Additionally, because these relationships were not properly disclosed, along with the fact that there was not a process in place for testing for these types of relationships, the procurement process failed to comply with the requirements set forth in the Uniform Guidance. Questioned Costs: The total amount of payments made to these subrecipients during the year ended June 30, 2020 was $128,161. $87,645 was paid from the Continuum of Care program and $40,507 from the Emergency Solutions Grant. Recommendation: Management has already taken appropriate corrective action by conducting the investigation related to these issues. The HRCS Director has retired from that position as of the issuance date of this report. We recommend that the City consider implementing a process to test for inappropriate relationships with vendors during the contracting process. We further recommend that the grant payments process, including review of subrecipient draw requests, be performed by the City?s Finance Department. View of Responsible Officials: A new HRCS director was hired in FY20 and began evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department. Also, we have implemented a contract review policy to prevent future conflicts of interest in city payments.
Show full finding ▾Hide full finding ▴2020-009 CONFLICT OF INTEREST - CITY PAYMENTS TO SUBRECIPIENTS (REPEAT COMMENT) Finding Type: Material Noncompliance/Material Weakness in Internal Control over Compliance (Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment, Subrecipient Monitoring, and Special Test and Provisions). Programs: Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; Award Numbers MI0417L5F081704 and MI0417L5F081805. Emergency Solutions Grant Program (ESG); U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Condition: The following issues were noted during grant compliance testing: COC & ESG Programs: The Human Resources and Community Services director and the director?s spouse were identified as being directors and/or on governing boards of subrecipient entities. Criteria: City policies, as well as clauses in external contracts and grant agreements, require reporting of any potential conflicts of interest related to payments to outside organizations for services provided to or on behalf of services provided by the City. Cause: The cause of this issue appears to be a lack of a process to test for relationships of this type when contracting with outside parties. Effect: As a result of this condition, the City HRCS Department was in violation of the City's internal conflict of interest policy, as well as conflict of interest clauses in the grant agreement related to the Continuum of Care and Emergency Solutions Grant programs. The fact that payments to these entities do not constitute an "arms length- transaction" causes the costs reported by these subrecipients to be in noncompliance with federal cost principles. Additionally, because these relationships were not properly disclosed, along with the fact that there was not a process in place for testing for these types of relationships, the procurement process failed to comply with the requirements set forth in the Uniform Guidance. Questioned Costs: The total amount of payments made to these subrecipients during the year ended June 30, 2020 was $128,161. $87,645 was paid from the Continuum of Care program and $40,507 from the Emergency Solutions Grant. Recommendation: Management has already taken appropriate corrective action by conducting the investigation related to these issues. The HRCS Director has retired from that position as of the issuance date of this report. We recommend that the City consider implementing a process to test for inappropriate relationships with vendors during the contracting process. We further recommend that the grant payments process, including review of subrecipient draw requests, be performed by the City?s Finance Department. View of Responsible Officials: A new HRCS director was hired in FY20 and began evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department. Also, we have implemented a contract review policy to prevent future conflicts of interest in city payments.
2020-009 CITY PAYMENTS TO SUBRECIPIENTS Management Assessment: We concur with the audit assessment regarding this matter. Planned Corrective Action: A new HRCS director was hired in FY20 and began evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department. Also, we have implemented a contract review policy to prevent future conflicts of interest in city payments. Responsible Party: HRCS Director and OCA Date of Planned Corrective Action: Ongoing
2019-004
Although the City has processes in place to cover these areas, there are no formal written policies covering payments, procurement and allowability of costs that address all of the areas required by the Uniform Guidance. The City does have a written conflict of interest policy in place related to the procurement process. Criteria: The Uniform 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 various areas, including: 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) Procurement (including bidding and a conflict of interest policy) (?200.318); and 3) Allowability of costs charged to federal programs (?200.302 (7)). Cause: This condition appears to be the result of a time lag in identifying the requirements and developing a plan for compliance. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs or excess cash draws. Recommendation: We recommend that the City draft the required policies as soon as practical, but no later than the end of fiscal year 2021. View of Responsible Officials: The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward.
Show full finding ▾Hide full finding ▴2020-010 WRITTEN POLICIES REQUIRED BY UNIFORM GRANT GUIDANCE (REPEAT COMMENT) Finding Type: Immaterial Noncompliance (Allowable Costs/Cost Principles, Cash Management, and Procurement Suspension and Debarment). Programs: Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; All Award Numbers Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Home Investment Partnerships Program; U.S. Department of Housing and Urban Development; CFDA Number 14.239; All Award Numbers. Clean Water State Revolving Fund Cluster; Environmental Protection Agency; CFDA Numbers 66.458 and 66.482; All Award Numbers. Condition: Although the City has processes in place to cover these areas, there are no formal written policies covering payments, procurement and allowability of costs that address all of the areas required by the Uniform Guidance. The City does have a written conflict of interest policy in place related to the procurement process. Criteria: The Uniform 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 various areas, including: 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) Procurement (including bidding and a conflict of interest policy) (?200.318); and 3) Allowability of costs charged to federal programs (?200.302 (7)). Cause: This condition appears to be the result of a time lag in identifying the requirements and developing a plan for compliance. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs or excess cash draws. Recommendation: We recommend that the City draft the required policies as soon as practical, but no later than the end of fiscal year 2021. View of Responsible Officials: The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward.
2020-010 WRITTEN POLICIES REQUIRED BY UNIFORM GUIDANCE Management Assessment: We concur with the audit assessment regarding this matter. Planned Corrective Action: The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward. Responsible Party: The Grant Accountant will work with all departments named in the finding with assistance from the OCA. Date of Planned Corrective Action: June 30, 2021
2019-008
Multiple disbursements were not made within the required 30 days from receiving request for reimbursement from subrecipients. Criteria: The City must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. Cause: This condition appears to be the result of a greater amount of time required for approval of disbursements than the grant requirements allow based on effects of the COVID-19 global pandemic. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: The total amount of disbursements that were not disbursed within the required 30 days for the year ended June 30, 2020 was $77,692. Recommendation: We recommend that the City review its internal processes in relation to this requirement and adjust so as to comply with the obligation, expenditure, and payment requirements. View of Responsible Officials: The Human Relations and Community Services Department has plans to hire an additional leadership staff member to help with the workflow of timely payments processing. The additional staff member will help with creating a checks and balance for grant expenditures and reimbursement. This person will work with the Grant Accountant regarding HRCS grant accounts.
Show full finding ▾Hide full finding ▴2020-011 OBLIGATION, EXPENDITURE, AND PAYMENT REQUIREMENTS Finding Type: Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Test and Provisions). Programs: Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Condition: Multiple disbursements were not made within the required 30 days from receiving request for reimbursement from subrecipients. Criteria: The City must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. Cause: This condition appears to be the result of a greater amount of time required for approval of disbursements than the grant requirements allow based on effects of the COVID-19 global pandemic. Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs: The total amount of disbursements that were not disbursed within the required 30 days for the year ended June 30, 2020 was $77,692. Recommendation: We recommend that the City review its internal processes in relation to this requirement and adjust so as to comply with the obligation, expenditure, and payment requirements. View of Responsible Officials: The Human Relations and Community Services Department has plans to hire an additional leadership staff member to help with the workflow of timely payments processing. The additional staff member will help with creating a checks and balance for grant expenditures and reimbursement. This person will work with the Grant Accountant regarding HRCS grant accounts.
2020-011 OBLIGATION, EXPENDITURE, AND PAYMENT REQUIREMENTS Management Assessment: We concur with the audit assessment regarding this matter. Planned Corrective Action: The Human Relations and Community Services Department has plans to hire an additional leadership staff member to help with the workflow of timely payments processing. The additional staff member will help with the creating a checks and balance for grant expenditures and reimbursement. This person will work with the Grant Accountant regarding HRCS grant accounts. Responsible Party: The Grant Accountant & HRCS Director Date of Planned Corrective Action: June 30, 2021
FAC accepted this audit on March 30, 2020 — management decision was due September 30, 2020.
2019-005 - Conflict of Interest - City Payments to Subrecipients Finding Type. Material noncompliance / Material Weakness in Internal Control over Compliance (Allowable Costs/Cost Principles, Procurement and Suspension and Debarment, and Subrecipient Monitoring). Programs. Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; Award Number MI0417L5F081704. Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Criteria. City policies, as well as clauses in external contracts and grant agreements, require reporting of any potential conflicts of interest related to payments to outside organizations for services provided to or on behalf of services provided by the City. Condition. The following issues were noted during grant compliance testing: Continuum of Care Program ? The Human Resources and Community Services (HRCS) Director was identified on a monitoring checklist as the Director of a subrecipient entity. ? The HCRS Director was also noted as Executive Director in the subrecipient Organization Chart (her daughter is also listed as a Director). ? The HRCS Director signed checks, on behalf of the subrecipient, submitted in support of subrecipient reimbursement requests. ? The HCRS Director signed off on the subrecipient agreement and subrecipient reporting, as evidence of independent review and approval, as the HCRS Director. ? The subrecipient's form 990-EZ, included in the grant file was also signed, on behalf of the subrecipient, by the HRCS Director. ? We noted that conflict of interest questions included in a subrecipient monitoring compliance checklist were marked "N/A", and contained the comment "No incident reported to recipient". Emergency Solutions Grant Program ? The spouse of the HRCS Director is identified in the State of Michigan annual filing as being a member of the governing board of one of this program's subrecipient entities. Cause. The cause of this issue appears to be the lack of a process to test for relationships of this type when contracting with outside parties. Effect. As a result of this condition, the City HRCS Department was in violation of the City's internal conflict of interest policy, as well as conflict of interest clauses in the grant agreement related to the Continuum of Care and Emergency Solutions Grant programs. The fact that payments to these entities do not constitute an "arms-length-transaction" causes the costs reported by these subrecipients to be in noncompliance with federal cost principles. Additionally, because these relationships were not properly disclosed, along with the fact that there does not appear to be a process in place for testing for these types of relationships, the procurement process fails to comply with the requirements set forth in the Uniform Guidance. Questioned Costs. The total amount of payments made to these subrecipients over the year ended June 30, 2019 was $233,710. $195,747 was paid from the Continuum of Care program and $37,963 from the Emergency Solutions Grants. Recommendation. Management has already taken appropriate corrective action by conducting the investigation related to these issues. The HRCS Director has retired from that position as of the issuance date of this report. We recommend that the City consider implementing a process to test for inappropriate relationships with vendors during the contracting process. We further recommend that the grant payments process, including review of subrecipient draw requests be performed by the City's Finance Department. View of Responsible Officials. A new HRCS director has been hired and will be evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department.
Show full finding ▾Hide full finding ▴2019-005 - Conflict of Interest - City Payments to Subrecipients Finding Type. Material noncompliance / Material Weakness in Internal Control over Compliance (Allowable Costs/Cost Principles, Procurement and Suspension and Debarment, and Subrecipient Monitoring). Programs. Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; Award Number MI0417L5F081704. Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Criteria. City policies, as well as clauses in external contracts and grant agreements, require reporting of any potential conflicts of interest related to payments to outside organizations for services provided to or on behalf of services provided by the City. Condition. The following issues were noted during grant compliance testing: Continuum of Care Program ? The Human Resources and Community Services (HRCS) Director was identified on a monitoring checklist as the Director of a subrecipient entity. ? The HCRS Director was also noted as Executive Director in the subrecipient Organization Chart (her daughter is also listed as a Director). ? The HRCS Director signed checks, on behalf of the subrecipient, submitted in support of subrecipient reimbursement requests. ? The HCRS Director signed off on the subrecipient agreement and subrecipient reporting, as evidence of independent review and approval, as the HCRS Director. ? The subrecipient's form 990-EZ, included in the grant file was also signed, on behalf of the subrecipient, by the HRCS Director. ? We noted that conflict of interest questions included in a subrecipient monitoring compliance checklist were marked "N/A", and contained the comment "No incident reported to recipient". Emergency Solutions Grant Program ? The spouse of the HRCS Director is identified in the State of Michigan annual filing as being a member of the governing board of one of this program's subrecipient entities. Cause. The cause of this issue appears to be the lack of a process to test for relationships of this type when contracting with outside parties. Effect. As a result of this condition, the City HRCS Department was in violation of the City's internal conflict of interest policy, as well as conflict of interest clauses in the grant agreement related to the Continuum of Care and Emergency Solutions Grant programs. The fact that payments to these entities do not constitute an "arms-length-transaction" causes the costs reported by these subrecipients to be in noncompliance with federal cost principles. Additionally, because these relationships were not properly disclosed, along with the fact that there does not appear to be a process in place for testing for these types of relationships, the procurement process fails to comply with the requirements set forth in the Uniform Guidance. Questioned Costs. The total amount of payments made to these subrecipients over the year ended June 30, 2019 was $233,710. $195,747 was paid from the Continuum of Care program and $37,963 from the Emergency Solutions Grants. Recommendation. Management has already taken appropriate corrective action by conducting the investigation related to these issues. The HRCS Director has retired from that position as of the issuance date of this report. We recommend that the City consider implementing a process to test for inappropriate relationships with vendors during the contracting process. We further recommend that the grant payments process, including review of subrecipient draw requests be performed by the City's Finance Department. View of Responsible Officials. A new HRCS director has been hired and will be evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department.
2019-005 - Conflict of Interest - City Payments to Subrecipients Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. A new HRCS director has been hired and will be evaluating processes and procedures in the department. In addition, an investigation is ongoing by the office of the State Attorney General, with which we are fully cooperating. We are working with the Office of the City Attorney (OCA) on this investigation, and once their final report is issued, we will take whatever steps are necessary to improve processes and procedures in the department. Responsible Party. HRCS Director Date of Planned Corrective Action. Ongoing
2019-006 - Interdepartmental Rental of Facilities Finding Type. Immaterial noncompliance / Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Community Development Block Grant - Entitlement Grants Cluster (CDBG) U.S. Department of Housing and Urban Development; CFDA Number 14.218; Award Number B-18-MC-26-0025. Criteria. Per 2 CFR 200.465(c), rental costs under "less-than-arm's-length" leases are allowable only up the amount that would be allowed if the non-federal entity owned the property, including expenses such as depreciation (subject to related limits), maintenance, taxes and insurances. Condition. The City charged to the CDBG grant a monthly rental charge for facilities owned by the City without having documentation of the actual costs related to the facility to support the amount of the charge. Cause. The cause of this issue appears to be the lack of understanding related to the principles around the charging of interdepartmental rental of facilities to federal awards. Effect. As a result of this condition, the City charged amounts to the CDBG grant that were not supported by documentation of actual costs incurred. Questioned Costs. The total amount of rent charged to the CDBG grant for the year ended June 30, 2019 was $29,612. Recommendation. We recommend that the City track and report to CDBG grant staff the cost of operating and maintaining City-owned property rented for administration of the program, and that any rent charged to the program be limited to the total of these costs. View of Responsible Officials. The City Finance Department will work with the Development Office to track and calculate the cost of operating and maintaining City-owned property rented for administration of the program, so that any rental charged to the program will be limited to the total of these costs and properly documented.
Show full finding ▾Hide full finding ▴2019-006 - Interdepartmental Rental of Facilities Finding Type. Immaterial noncompliance / Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Community Development Block Grant - Entitlement Grants Cluster (CDBG) U.S. Department of Housing and Urban Development; CFDA Number 14.218; Award Number B-18-MC-26-0025. Criteria. Per 2 CFR 200.465(c), rental costs under "less-than-arm's-length" leases are allowable only up the amount that would be allowed if the non-federal entity owned the property, including expenses such as depreciation (subject to related limits), maintenance, taxes and insurances. Condition. The City charged to the CDBG grant a monthly rental charge for facilities owned by the City without having documentation of the actual costs related to the facility to support the amount of the charge. Cause. The cause of this issue appears to be the lack of understanding related to the principles around the charging of interdepartmental rental of facilities to federal awards. Effect. As a result of this condition, the City charged amounts to the CDBG grant that were not supported by documentation of actual costs incurred. Questioned Costs. The total amount of rent charged to the CDBG grant for the year ended June 30, 2019 was $29,612. Recommendation. We recommend that the City track and report to CDBG grant staff the cost of operating and maintaining City-owned property rented for administration of the program, and that any rent charged to the program be limited to the total of these costs. View of Responsible Officials. The City Finance Department will work with the Development Office to track and calculate the cost of operating and maintaining City-owned property rented for administration of the program, so that any rental charged to the program will be limited to the total of these costs and properly documented.
2019-006 - Interdepartmental Rental of Facilities Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. The City Finance Department will work with the Development Office to track and calculate the cost of operating and maintaining City-owned property rented for administration of the program, so that any rental charged to the program will be limited to the total of these costs and properly documented. Responsible Party. Grant Accountant Date of Planned Corrective Action. June 30, 2020
2019-007 - Lack of Support for Matching Funds - Subrecipients Finding Type. Immaterial noncompliance / Significant Deficiency in Internal Control over Compliance (Matching, Level of Effort and Earmarking). Program. Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; Award Numbers MI0582L5F081700 and MI0507L5F081601. Criteria. During-the-award monitoring of subrecipients should provide reasonable assurance that the subrecipient has adhered to all compliance areas that are direct and material to the grant being passed-through. Condition. For two of the fourteen grant files tested, we were not able to verify the matching funds provided by the associated subrecipients. The files contained summaries of matching amounts provided, but appropriate documentation to support the amounts claimed was not attached. Cause. The cause of this issue appears to be the lack of appropriate communication with these subrecipients as to the reporting requirements associated with the matching funds to be provided by the subrecipient. Effect. As a result of this condition, the City did not have reasonable assurance that the matching funds for these programs were from allowable sources. 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 or excess cash draws. Recommendation. We recommend that the City reach out to the subrecipients associated with these grants and communicate the importance of providing appropriate detailed support for matching funds. In addition, we recommend that payments to subrecipients be withheld when incomplete documentation is not provided related to matching funds claimed. View of Responsible Officials. A new HRCS director has been hired and will be evaluating processes and procedures in the department including obtaining appropriate documentation from subrecipients for matching funds. The Finance department will review these procedures to insure they are in compliance.
Show full finding ▾Hide full finding ▴2019-007 - Lack of Support for Matching Funds - Subrecipients Finding Type. Immaterial noncompliance / Significant Deficiency in Internal Control over Compliance (Matching, Level of Effort and Earmarking). Program. Continuum of Care Program (COC); U.S. Department of Housing and Urban Development (HUD); CFDA Number 14.267; Award Numbers MI0582L5F081700 and MI0507L5F081601. Criteria. During-the-award monitoring of subrecipients should provide reasonable assurance that the subrecipient has adhered to all compliance areas that are direct and material to the grant being passed-through. Condition. For two of the fourteen grant files tested, we were not able to verify the matching funds provided by the associated subrecipients. The files contained summaries of matching amounts provided, but appropriate documentation to support the amounts claimed was not attached. Cause. The cause of this issue appears to be the lack of appropriate communication with these subrecipients as to the reporting requirements associated with the matching funds to be provided by the subrecipient. Effect. As a result of this condition, the City did not have reasonable assurance that the matching funds for these programs were from allowable sources. 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 or excess cash draws. Recommendation. We recommend that the City reach out to the subrecipients associated with these grants and communicate the importance of providing appropriate detailed support for matching funds. In addition, we recommend that payments to subrecipients be withheld when incomplete documentation is not provided related to matching funds claimed. View of Responsible Officials. A new HRCS director has been hired and will be evaluating processes and procedures in the department including obtaining appropriate documentation from subrecipients for matching funds. The Finance department will review these procedures to insure they are in compliance.
2019-007 ? Lack of Support for Matching Funds - Subrecipients Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. A new HRCS director has been hired and will be evaluating processes and procedures in the department including obtaining appropriate documentation from subrecipients for matching funds. The Finance department will review these procedures to insure they are in compliance. Responsible Party. HRCS Director & Grant Accountant Date of Planned Corrective Action. June 30, 2020
2019-008 ? Written Policies Required by the Uniform Grant Guidance (Repeat Comment) Finding Type. Immaterial Noncompliance (Allowable Costs/Cost Principles, Cash Management and Procurement and Suspension and Debarment). Programs. Community Development Block Grant - Entitlement Grants Cluster; U.S. Department of Housing and Urban Development; CFDA Number 14.218; All Award Numbers. Lead Hazard Reduction Demonstration Program; U.S. Department of Housing and Urban Development; CFDA Number 14.905; Award Number MILHD 0302-16. Continuum of Care Program; U.S. Department of Housing and Urban Development; CFDA Number 14.267; All Award Numbers. Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Criteria. The Uniform 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 various areas, including: 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) Procurement (including bidding and a conflict of interest policy) (?200.318); and 3) Allowability of costs charged to federal programs (?200.302 (7)). Condition. Although the City has processes in place to cover these areas, there are no formal written policies covering payments, procurement and allowability of costs that address all of the areas required by the Uniform Guidance. The City does have a written conflict of interest policy in place related to the procurement process. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 or excess cash draws. Recommendation. We recommend that the City draft the required policies as soon as practical, but no later than the end of fiscal year 2020. View of Responsible Officials. The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward.
Show full finding ▾Hide full finding ▴2019-008 ? Written Policies Required by the Uniform Grant Guidance (Repeat Comment) Finding Type. Immaterial Noncompliance (Allowable Costs/Cost Principles, Cash Management and Procurement and Suspension and Debarment). Programs. Community Development Block Grant - Entitlement Grants Cluster; U.S. Department of Housing and Urban Development; CFDA Number 14.218; All Award Numbers. Lead Hazard Reduction Demonstration Program; U.S. Department of Housing and Urban Development; CFDA Number 14.905; Award Number MILHD 0302-16. Continuum of Care Program; U.S. Department of Housing and Urban Development; CFDA Number 14.267; All Award Numbers. Emergency Solutions Grant Program; U.S. Department of Housing and Urban Development; CFDA Number 14.231; All Award Numbers. Criteria. The Uniform 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 various areas, including: 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) Procurement (including bidding and a conflict of interest policy) (?200.318); and 3) Allowability of costs charged to federal programs (?200.302 (7)). Condition. Although the City has processes in place to cover these areas, there are no formal written policies covering payments, procurement and allowability of costs that address all of the areas required by the Uniform Guidance. The City does have a written conflict of interest policy in place related to the procurement process. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. 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 or excess cash draws. Recommendation. We recommend that the City draft the required policies as soon as practical, but no later than the end of fiscal year 2020. View of Responsible Officials. The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward.
2019-008 ? Written Policies Required by the Uniform Grant Guidance Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. The Finance Department will work with all of the departments named in this finding including Economic Development and Planning and HRCS director to draft the required written policies as noted in this audit finding. We will review these policies with the OCA to make sure that we are in compliance going forward. Responsible Party. The Grant Accountant will work with all departments named in this finding with assistance from the OCA. Date of Planned Corrective Action. June 30, 2020
2018-004
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
GSA_MIGRATION
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2017-003
FAC accepted this audit on March 30, 2018 — management decision was due September 30, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-003
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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