EIN: 611736056
UEI: GD8LN4GNN1L4
Audited by: GABRIDGE & COMPANY, PLC
Oversight agency: 84 [Department of Education]
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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 February 4, 2025. 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 August 4, 2025 (392 days ago).
What is a management decision? →FAC accepted this audit on October 1, 2023 — management decision was due April 1, 2024.
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.
During our detailed testing of cash disbursements for the Twenty-First Century Community Learning Centers program, we noted that vendor invoices could not be located for certain transactions. In addition, vendor invoices were approved for payment after the cash disbursement checks were issued. Furthermore, the program budgets, which included Brinks debit card transactions, were not formally approved by the Board of Directors. Context: Of the 40 cash disbursements selected for testing, two vendor invoices could not be located. Of the 13 disbursements with vendor invoices, the invoices for 12 selections were approved by the Chief Professional Officer with documented approval after the cash disbursement checks were issued, not in advance as required by the Organization?s cash disbursements policy. Additionally, one invoice tested was missing a second documented approval by a Board member in accordance with the policy. Of the 27 Brinks debit card transactions tested, none of the debit card transactions were approved by a Board member in accordance with the Organization?s cash disbursements policy. Available funding in the program budgets serves as authorization for the debit card transactions, but the program budgets are not formally approved by the Board of Directors. The sample was not a statistically valid sample. Effect: Failure to properly file and maintain vendor invoices could result in the Organization?s inability to substantiate that the charges were for legitimate business purposes or for allowable activities under the grant. Reviewing vendor invoices after the issuance of checks or not having a second review performed by a Board member could result in payments for goods or services that are not legitimate business transactions or for items that are not allowed under the grant. Not having the program budget be formally approved by the Board of Directors and closely monitored with documented approval could result in excess costs be charged to the grant, especially with debit card transactions. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly file and maintain vendor invoices, review vendor invoices within the necessary time frame, and formally approve the program budget. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should educate all employees involved in the cash disbursements process of the Organization?s policy surrounding cash disbursements. The Organization should closely follow its established cash disbursements policy to file and maintain vendor invoices and have them reviewed by the appropriate levels of management and a Board member prior to the issuance of checks. In addition, the Organization should also establish a procedure to require the program budget to be formally approved by the Board of Directors and document the monitoring of budget-to-actual activity on a regular basis. Views of Responsible Officials: The Organization agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2020-003: Twenty-First Century Community Learning Centers Cash Disbursements Procedures Pass-through entity: Michigan Department of Education (MDE) CFDA/Assistance Listing Number(s): 84.287C Award Numbers: 202110-K181580, 202110-L194317, 212110-K181580 and 212110-L194317 Award Year Ends: June 30, 2020 and 2021 Specific Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity to establish and maintain effective internal control over the Federal award that provides a reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination. Questioned Costs: None. Condition: During our detailed testing of cash disbursements for the Twenty-First Century Community Learning Centers program, we noted that vendor invoices could not be located for certain transactions. In addition, vendor invoices were approved for payment after the cash disbursement checks were issued. Furthermore, the program budgets, which included Brinks debit card transactions, were not formally approved by the Board of Directors. Context: Of the 40 cash disbursements selected for testing, two vendor invoices could not be located. Of the 13 disbursements with vendor invoices, the invoices for 12 selections were approved by the Chief Professional Officer with documented approval after the cash disbursement checks were issued, not in advance as required by the Organization?s cash disbursements policy. Additionally, one invoice tested was missing a second documented approval by a Board member in accordance with the policy. Of the 27 Brinks debit card transactions tested, none of the debit card transactions were approved by a Board member in accordance with the Organization?s cash disbursements policy. Available funding in the program budgets serves as authorization for the debit card transactions, but the program budgets are not formally approved by the Board of Directors. The sample was not a statistically valid sample. Effect: Failure to properly file and maintain vendor invoices could result in the Organization?s inability to substantiate that the charges were for legitimate business purposes or for allowable activities under the grant. Reviewing vendor invoices after the issuance of checks or not having a second review performed by a Board member could result in payments for goods or services that are not legitimate business transactions or for items that are not allowed under the grant. Not having the program budget be formally approved by the Board of Directors and closely monitored with documented approval could result in excess costs be charged to the grant, especially with debit card transactions. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly file and maintain vendor invoices, review vendor invoices within the necessary time frame, and formally approve the program budget. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should educate all employees involved in the cash disbursements process of the Organization?s policy surrounding cash disbursements. The Organization should closely follow its established cash disbursements policy to file and maintain vendor invoices and have them reviewed by the appropriate levels of management and a Board member prior to the issuance of checks. In addition, the Organization should also establish a procedure to require the program budget to be formally approved by the Board of Directors and document the monitoring of budget-to-actual activity on a regular basis. Views of Responsible Officials: The Organization agrees with this finding.
Finding 2020-003: Twenty-First Century Community Learning Centers Cash Disbursements Procedures Recommendation: The Organization should educate all employees involved in the cash disbursements process of the Organization?s policy surrounding cash disbursements. The Organization should closely follow its established cash disbursements policy to file and maintain vendor invoices and have them reviewed by the appropriate levels of management and a Board member prior to the issuance of checks. In addition, the Organization should also establish a procedure to require the program budget to be formally approved by the Board of Directors and document the monitoring of budget-to-actual activity on a regular basis. Action Taken: The inclusion of an on-site staff accountant has helped the Organization maintain vendor files and implement more stringent approval and cash disbursement policies. The Organization began using the Bill.com accounts payable system in September 2021 for all invoice-generated payables, which requires digital approval from the CPO and Board Treasurer before funds can be released for payment. Program budgets with federal funding that include Brinks debit card expenditures will require approval from the CPO and Board Treasurer and will be maintained by the Area Operations Director. On a monthly basis, the CPO and Board Treasurer will review and approve the Brinks debit card transactions. The Board approves the financial statements on a monthly basis, which include the expenses applied to grants. Responsible Person and Anticipated Completion Date: The CFO is responsible for educating all employees on cash disbursement policies and for maintenance of the disbursement receipts. The CFO is also responsible for ensuring that proper approval is obtained for disbursements prior to payment. The CPO and Board Treasurer will be responsible for approving program-level budgets, and the Area Operations Director will be responsible for approving program-level purchases that are within each approved program-level budget. The CFO will be responsible for verifying that all disbursements have been approved before submitting reimbursements or payments. This process will be documented and enacted by March 31, 2022.
During our detailed testing of personnel activity reports for the Twenty-First Century Community Learning Centers program, we noted that the original personnel activity reports prepared for employees working in the program were not properly prepared in accordance with federal time and effort requirements despite the fact that they were all reviewed by employee supervisors with documented approval. The corrected personnel activity reports were based on actual work allocations and contained all of the proper components. However, the corrected reports were not timely prepared. Context: Twenty-one employees working in the federal program were required to complete personnel activity reports. Of the seven employees selected for testing, the reports for all seven employees contained the proper components. They reflected after-the-fact distributions of the actual activity for each employee. They accounted for the total activity for which the employees were compensated. They were reconciled to the accounting records to ensure the federal grants were not overcharged for employee wages and benefits, and the reports were properly signed by employee supervisors. However, the corrected reports were not deemed to be timely prepared as they were prepared by employees from payroll records during the audit process. The sample was not a statistically valid sample. Effect: Failure to timely and properly prepare and review personnel activity reports could allow improper payroll expenses to be charged to the Organization?s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The Organization misunderstood the federal requirements for personnel activity reports, and the personnel activity reports were not timely and properly prepared. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the Organization should require appropriate time and effort documentation and necessary reconciliations to payroll records to be timely and properly prepared and reviewed. Views of Responsible Officials: The Organization agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2020-004: Twenty-First Century Community Learning Centers Personnel Activity Report Procedures Pass-through entity: Michigan Department of Education (MDE) CFDA/Assistance Listing Number(s): 84.287C Award Numbers: 202110-K181580, 202110-L194317, 212110-K181580 and 212110-L194317 Award Year Ends: June 30, 2020 and 2021 Specific Requirement: Allowable Costs/Cost Principles Criteria: Section 200.430 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee?s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. Questioned Costs: None. Condition: During our detailed testing of personnel activity reports for the Twenty-First Century Community Learning Centers program, we noted that the original personnel activity reports prepared for employees working in the program were not properly prepared in accordance with federal time and effort requirements despite the fact that they were all reviewed by employee supervisors with documented approval. The corrected personnel activity reports were based on actual work allocations and contained all of the proper components. However, the corrected reports were not timely prepared. Context: Twenty-one employees working in the federal program were required to complete personnel activity reports. Of the seven employees selected for testing, the reports for all seven employees contained the proper components. They reflected after-the-fact distributions of the actual activity for each employee. They accounted for the total activity for which the employees were compensated. They were reconciled to the accounting records to ensure the federal grants were not overcharged for employee wages and benefits, and the reports were properly signed by employee supervisors. However, the corrected reports were not deemed to be timely prepared as they were prepared by employees from payroll records during the audit process. The sample was not a statistically valid sample. Effect: Failure to timely and properly prepare and review personnel activity reports could allow improper payroll expenses to be charged to the Organization?s federal programs. As a result, payroll compensation and fringe benefits charged for these employees could be disallowed, or there could be missed opportunities for reimbursement. Cause: The Organization misunderstood the federal requirements for personnel activity reports, and the personnel activity reports were not timely and properly prepared. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the Organization should require appropriate time and effort documentation and necessary reconciliations to payroll records to be timely and properly prepared and reviewed. Views of Responsible Officials: The Organization agrees with this finding.
Finding 2020-004: Twenty-First Century Community Learning Centers Personnel Activity Report Procedures Recommendation: The Organization should educate all employees working in federal programs of the requirements for timely and properly documenting personnel expenses under Uniform Grant Guidance, and the Organization should require appropriate time and effort documentation and necessary reconciliations to payroll records to be timely and properly prepared and reviewed. Action Taken: A new procedure that complies with Uniform Grant Guidance was enacted as of July 1, 2021 to ensure the timely approval of personnel activity reports and all employees were informed of the requirements. All new-hire employees and employees moving into roles that require personnel activity reports are instructed in the procedure. Responsible Person and Anticipated Completion Date: The Chief Operating Officer (COO) or the Area Operations Director is responsible for ensuring that all required personnel activity reports are completed in a timely manner, are reconciled to the payroll records and approved within 30 days of each pay date. The CFO is responsible for obtaining approved records before expenses are reimbursed by the relevant grant.
During our detailed testing of the cash management area for the Twenty-First Century Community Learning Centers program, we noted that the requests for funds were missing documented approval. In addition, the cash draw for one month tested was over requested. The Organization identified the error in the subsequent month and reduced that month?s cash request accordingly. Context: The Organization submitted 39 requests for funds during the fiscal year in total for both cohorts. Eleven of the 12 requests selected for testing were missing documented approval by the Chief Professional Officer. In addition, the November 2020 request for funds for Cohort L was overstated due to a clerical error, and the cash request for December 2020 was reduced accordingly upon the detection of the error. The sample was not a statistically valid sample. Effect: Failure to properly prepare and review requests for funds could allow funds to be over requested and potentially overstate federal revenue resulting in excess funds paid to the Organization. In addition, there could also be missed opportunities for reimbursement. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly review all of the requests for funds that were submitted to MDE. In addition, the Organization?s cash management review process did not include an established procedure for the reviewer to verify the clerical accuracy of the reports. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should follow its established cash management review procedure that requires the documented review and approval of all requests for funds before they are submitted. In addition, the Organization should modify the review procedure to require the verification of the clerical accuracy of the reports. Views of Responsible Officials: The Organization agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2020-005: Twenty-First Century Community Learning Centers Cash Management Review Procedures Pass-through entity: Michigan Department of Education (MDE) CFDA/Assistance Listing Number(s): 84.287C Award Numbers: 202110-K181580, 202110-L194317, 212110-K181580 and 212110-L194317 Award Year Ends: June 30, 2020 and 2021 Specific Requirement: Cash Management Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity to establish and maintain effective internal control over the Federal award that provides a reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination. Questioned Costs: None. Condition: During our detailed testing of the cash management area for the Twenty-First Century Community Learning Centers program, we noted that the requests for funds were missing documented approval. In addition, the cash draw for one month tested was over requested. The Organization identified the error in the subsequent month and reduced that month?s cash request accordingly. Context: The Organization submitted 39 requests for funds during the fiscal year in total for both cohorts. Eleven of the 12 requests selected for testing were missing documented approval by the Chief Professional Officer. In addition, the November 2020 request for funds for Cohort L was overstated due to a clerical error, and the cash request for December 2020 was reduced accordingly upon the detection of the error. The sample was not a statistically valid sample. Effect: Failure to properly prepare and review requests for funds could allow funds to be over requested and potentially overstate federal revenue resulting in excess funds paid to the Organization. In addition, there could also be missed opportunities for reimbursement. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly review all of the requests for funds that were submitted to MDE. In addition, the Organization?s cash management review process did not include an established procedure for the reviewer to verify the clerical accuracy of the reports. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should follow its established cash management review procedure that requires the documented review and approval of all requests for funds before they are submitted. In addition, the Organization should modify the review procedure to require the verification of the clerical accuracy of the reports. Views of Responsible Officials: The Organization agrees with this finding.
Finding 2020-005: Twenty-First Century Community Learning Centers Cash Management Review Procedures Recommendation: The Organization should properly file copies of all reports submitted along with supporting documentation to substantiate that the reports were timely filed with the proper amounts so that they can be quickly located when needed. Action Taken: The addition of an on-site accountant has assisted with the compliance of the cash disbursement procedures. The expenses from the general ledger program expense detail are approved by the Area Operations Director or appropriate department director and compared to the budget before they are entered in the request for funds forms. The request for funds forms are generated from general ledger program expense detail. The reimbursements are compared and verified to the general ledger program expense detail by the COO or CPO to ensure accuracy. Responsible Person and Anticipated Completion Date: As of July 1, 2021, the CFO is responsible for ensuring that the requests for funds are created from approved and accurate General Ledger information. The COO and CPO are responsible for verifying accuracy of the requests for funds. The CFO will ensure that the internal control procedure for grants details the order of verification and entry to ensure accuracy by March 31, 2022.
During our detailed testing of the reporting area for the Twenty-First Century Community Learning Centers program, the selected final expenditure report filed during the fiscal year and supporting documentation could not be located. A copy of the selected report was subsequently obtained by the Organization from MDE and agreed to the Organization?s accounting records. However, it could not be verified if the report was reviewed with documented approval prior to submission to MDE. Context: One of two final expenditure reports filed by the Organization during the fiscal year was selected for testing. However, neither of the two reports filed during the year could be located along with the supporting documentation. Therefore, the original reports approved by the Chief Professional Officer could not be provided to the auditors upon their request for testing. The sample was not a statistically valid sample. Effect: Failure to properly file and maintain copies of reports filed and supporting documentation could result in the Organization?s inability to substantiate that the reports were timely filed with the proper amounts, resulting in a compliance finding. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly file copies of the reports that were submitted to MDE. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should properly file copies of all reports submitted along with supporting documentation to substantiate that the reports were timely filed with the proper amounts and so that they can be quickly located when needed. Views of Responsible Officials: The Organization agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2020-006: Twenty-First Century Community Learning Centers Reporting Review Procedures Pass-through entity: Michigan Department of Education (MDE) CFDA/Assistance Listing Number(s): 84.287C Award Numbers: 202110-K181580 and 202110-L194317 Award Year Ends: June 30, 2020 Specific Requirement: Reporting Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity to establish and maintain effective internal control over the Federal award that provides a reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination. Questioned Costs: None. Condition: During our detailed testing of the reporting area for the Twenty-First Century Community Learning Centers program, the selected final expenditure report filed during the fiscal year and supporting documentation could not be located. A copy of the selected report was subsequently obtained by the Organization from MDE and agreed to the Organization?s accounting records. However, it could not be verified if the report was reviewed with documented approval prior to submission to MDE. Context: One of two final expenditure reports filed by the Organization during the fiscal year was selected for testing. However, neither of the two reports filed during the year could be located along with the supporting documentation. Therefore, the original reports approved by the Chief Professional Officer could not be provided to the auditors upon their request for testing. The sample was not a statistically valid sample. Effect: Failure to properly file and maintain copies of reports filed and supporting documentation could result in the Organization?s inability to substantiate that the reports were timely filed with the proper amounts, resulting in a compliance finding. Cause: The Organization experienced personnel changes within key positions, leaving the Organization understaffed and unable to properly file copies of the reports that were submitted to MDE. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should properly file copies of all reports submitted along with supporting documentation to substantiate that the reports were timely filed with the proper amounts and so that they can be quickly located when needed. Views of Responsible Officials: The Organization agrees with this finding.
Finding 2020-006: Twenty-First Century Community Learning Centers Reporting Review Procedures Recommendation: The Organization should follow its established cash management review procedure that requires the documented review and approval of all requests for funds before they are submitted. In addition, the Organization should modify the review procedure to require the verification of the clerical accuracy of the reports. Action Taken: The procedure for review and submission of the final expenditure reports and grant amendments was reviewed and updated in procedure OPS0015?Internal Controls for Grants. Responsible Person and Anticipated Completion Date: The CFO updated the procedure with a March 15, 2022 effective date and is responsible for approval, verification, and retention of the final expenditure reports and grant amendments.
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