EIN: 841661509
UEI: G8WMY6KA21N3
Audited by: Hannah R Bond CPA PLLC
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 10, 2026. 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 10, 2026 (30 days ago).
What is a management decision? →FAC accepted this audit on January 29, 2025 — management decision was due July 29, 2025.
FAC accepted this audit on February 20, 2024 — management decision was due August 20, 2024.
Finding 2023-001 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- 18 tenant files were reviewed and the following discrepancies were noted: -2 tenant files did not perform timely recertifications -7 tenant files used incorrect income information, deductions, or assets that led to incorrect rent -2 tenant files used an incorrect Utility Allowance -2 tenant files were missing form 9886 -3 tenant files did not run EIV during recertification -5 tenant files were missing requests for tenancy approvals - 2 tenant files were missing recent HQS inspection results Questioned Cost- None Context- 24 CFR 982.451 addresses Signed HAP Contracts; 24 CFR 982.517 addresses utility allowances; other PIH notices, HUD handbooks, and CFR's address all other required forms. Effect- Tenant rents may be miscalculated, other notifications and documentation may be missing. Cause- PHA failed to sufficiently implement quality control procedures for newly trained staff members. Recommendation- The Housing Commission should effectively implement a policy to ensure compliance with HUD regulations concerning the Administrative Plan for the Housing Assistance Program; the above discrepancies must be addressed, and all tenant files should continue to be reviewed for proper compliance.
Show full finding ▾Hide full finding ▴Finding 2023-001 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- 18 tenant files were reviewed and the following discrepancies were noted: -2 tenant files did not perform timely recertifications -7 tenant files used incorrect income information, deductions, or assets that led to incorrect rent -2 tenant files used an incorrect Utility Allowance -2 tenant files were missing form 9886 -3 tenant files did not run EIV during recertification -5 tenant files were missing requests for tenancy approvals - 2 tenant files were missing recent HQS inspection results Questioned Cost- None Context- 24 CFR 982.451 addresses Signed HAP Contracts; 24 CFR 982.517 addresses utility allowances; other PIH notices, HUD handbooks, and CFR's address all other required forms. Effect- Tenant rents may be miscalculated, other notifications and documentation may be missing. Cause- PHA failed to sufficiently implement quality control procedures for newly trained staff members. Recommendation- The Housing Commission should effectively implement a policy to ensure compliance with HUD regulations concerning the Administrative Plan for the Housing Assistance Program; the above discrepancies must be addressed, and all tenant files should continue to be reviewed for proper compliance.
The RRHC has hired new staff for this position and staff has been certified. The RRHC will reimplement quality control processes to ensure the errors/discrepancies are corrected and/or minimized. The RRHC has implemented a 100% file review for all HCV participants. This review will ensure that all required documentation is in files and files are in the approved file format. In addition, on a monthly basis, a minimum of 20% of completed actions will be reviewed for accuracy and completion. And 100% of new admissions will be reviewed prior to issuance of voucher and again after execution of HAP contract.
2022-001
FAC accepted this audit on September 14, 2022 — management decision was due March 14, 2023.
CFDA 14.871 Housing Assistance Program Finding 2021-001 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- 9 tenant files were reviewed and the following discrepancies were noted: - 1 tenant file was not located or provided - 4 files did not have a current Housing Assistance Payments contract - 5 files did not have the correct Utility Allowance - 1 tenant file did not perform the recertification - 4 files did not have current leases - All files had missing required forms Questioned Cost- None Context- 24 CFR 982.451 addresses Signed HAP Contracts; 24 CFR 982.517 addresses utility allowances; other PIH notices, HUD handbooks, and CFR's address all other required forms. Effect- Tenant rents may be miscalculated, other notifications and documentations may be missing. Cause- The Occupancy Specialist is out on medical leave and the position was held until her return. After three months of vacancy, the Executive Director began the hiring process to fill the open position, however, has not been successful as of the date of the audit. Recommendation- The Housing Commission must fill the HCV Occupancy Specialist position immediately. Additionally, the Housing Commission should implement a policy to insure compliance with HUD regulations concerning the Administrative Plan for the Housing Assistance Program; the above discrepancies must be addressed, and all tenant files should be reviewed for proper compliance.
Show full finding ▾Hide full finding ▴CFDA 14.871 Housing Assistance Program Finding 2021-001 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- 9 tenant files were reviewed and the following discrepancies were noted: - 1 tenant file was not located or provided - 4 files did not have a current Housing Assistance Payments contract - 5 files did not have the correct Utility Allowance - 1 tenant file did not perform the recertification - 4 files did not have current leases - All files had missing required forms Questioned Cost- None Context- 24 CFR 982.451 addresses Signed HAP Contracts; 24 CFR 982.517 addresses utility allowances; other PIH notices, HUD handbooks, and CFR's address all other required forms. Effect- Tenant rents may be miscalculated, other notifications and documentations may be missing. Cause- The Occupancy Specialist is out on medical leave and the position was held until her return. After three months of vacancy, the Executive Director began the hiring process to fill the open position, however, has not been successful as of the date of the audit. Recommendation- The Housing Commission must fill the HCV Occupancy Specialist position immediately. Additionally, the Housing Commission should implement a policy to insure compliance with HUD regulations concerning the Administrative Plan for the Housing Assistance Program; the above discrepancies must be addressed, and all tenant files should be reviewed for proper compliance.
The intent of this letter is to provide the corrective action plans for curing the findings cited in the River Rouge Housing Commission?s audit for fiscal year ending June 30, 2021. Finding 2018-001 & 2021-001 Housing Assistance Program Discrepancies These findings are being combined as it is a repeat finding. As mentioned within 2021-001, the RRHC is looking to fill the HCV Coordinator position. The agency has previously implemented a quality control system to review HAP calculation and ensure the agency is in compliance with HUD?s regulations and our policies. Once the position is filled, the staff member will be required to take a rent calculation course and pass with a minimum of 80% within the initial 90-day probationary period. Afterwards, a certain percentage of annual/interim certifications will be reviewed on a monthly basis. Any errors found during the review will be corrected within 48 hours of notice. For eligibility, all files will be reviewed prior to issuing a voucher. Finding 2018-002 Capital Projects Fund Program Discrepancies The agency was working with the Field Office to close this finding. The RRHC has updated its Maintenance Plan and Procurement Policy to address the criteria for an emergency. The agency will continue to work with the FO to close out finding. Finding 2019-001 Governance and Board Actions The RRHC has devised and approved the Commission?s By-Law with resolution #500 dated July 14, 2020. In addition, two of the Commissioners attended a strategic planning retreat in May 2022. During the retreat, the presenters reiterated that staffing and management are the Executive Director?s responsibility. We will work with the FO to get finding closed. Finding 2020-001 Low Rent Housing Program Discrepancies As with findings 2018-001 and 2021-001, the agency has implemented a quality control system to review tenant rent calculations and ensure the agency is in compliance with HUD?s regulations and our own policies. Currently, the agency is looking to fill the Public Housing Manager position as the current employee is part time due to acceptance of an executive level position with another agency. The new employee will be required to take rent calculation course and pass with a minimum of 80% within the initial 90-day probationary period. The agency will work with the FO to close out this finding as it was repeated due to the FO not closing out the finding. Finding 2020-003 Capital Projects Fund Program Discrepancies The current CFP Coordinator has attended training regarding Capital Funds and the wage requirements. The agency includes the current Davis Bacon wages in all CFP bids and contractors are interviewed to ensure the proper rates are being paid. The agency will work with the FO to close out finding as it was repeated due to the FO not closing out the finding.
FAC accepted this audit on March 22, 2021 — management decision was due September 22, 2021.
Finding 2020-001 Low Rent Housing Program Discrepancies Criteria- Several PIH notices and CFR?s address compliance requirements within the Public Housing Program; some discrepancies were noted during the review of tenant files. Condition- I reviewed 10 tenant files, the following discrepancies were noted: -3 of the 10 files did not have a current HUD Authorization form HUD 9886 -5 of the 10 files were re-examined late -5 of the 10 files did not contain Community Service documentation -none of the files had an inspection performed in 2020 -some other files had missing required forms like Rent Choice, a Birth Certificate, a social security number verification -The Commission has not conducted a utility allowance survey or adjusted utility allowances in over three years.
Show full finding ▾Hide full finding ▴Finding 2020-001 Low Rent Housing Program Discrepancies Criteria- Several PIH notices and CFR?s address compliance requirements within the Public Housing Program; some discrepancies were noted during the review of tenant files. Condition- I reviewed 10 tenant files, the following discrepancies were noted: -3 of the 10 files did not have a current HUD Authorization form HUD 9886 -5 of the 10 files were re-examined late -5 of the 10 files did not contain Community Service documentation -none of the files had an inspection performed in 2020 -some other files had missing required forms like Rent Choice, a Birth Certificate, a social security number verification -The Commission has not conducted a utility allowance survey or adjusted utility allowances in over three years.
River Rouge Housing Commission agrees with the finding; we will correct the audited files. In addition, will hire a third party firm to randomly select and review tenant files. Will continue to train staff to avoid discrepancies.
Finding 2020-002 Excessive Tenant Accounts Receivable Criteria- The Wuhan Covid virus forced temporary closures of Offices and restricted in person contact with tenants; evictions were temporarily prohibited, many jobs were lost. Tenants that had a change of income due to the above were required to notify the Commission so adjustments could be made to their rent; however, tenants were still expected to pay rent. Condition- Many tenants stopped paying rent once it became known that the courts were closed and they could not be evicted; tenant accounts receivable have increased from $ 47,462 to $ 105,580.
Show full finding ▾Hide full finding ▴Finding 2020-002 Excessive Tenant Accounts Receivable Criteria- The Wuhan Covid virus forced temporary closures of Offices and restricted in person contact with tenants; evictions were temporarily prohibited, many jobs were lost. Tenants that had a change of income due to the above were required to notify the Commission so adjustments could be made to their rent; however, tenants were still expected to pay rent. Condition- Many tenants stopped paying rent once it became known that the courts were closed and they could not be evicted; tenant accounts receivable have increased from $ 47,462 to $ 105,580.
Housing Commission agrees with finding; the majority of the excess accounts receivable was created by the COVID pandemic. HUD instituted the Rent Eviction Moratorium which has not helped matters; we are instituting stricter collection policies and will try to collect all accounts.
CFDA 14.872 Capital Projects Funds Finding 2020-003 Capital Projects Fund Program Discrepancies Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also require certified payrolls. The Commission has the responsibility to review those payrolls to insure the proper classifications are used for employees, and the proper rates and fringe benefits are paid. Condition- The Commission did not follow the above criteria using CFP money; a contract was entered into, interviews conducted, however, the Davis Bacon Wage rates provided to the contractor were outdated, issued in 2010. In addition, no mention of fringe benefits was provided.
Show full finding ▾Hide full finding ▴CFDA 14.872 Capital Projects Funds Finding 2020-003 Capital Projects Fund Program Discrepancies Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also require certified payrolls. The Commission has the responsibility to review those payrolls to insure the proper classifications are used for employees, and the proper rates and fringe benefits are paid. Condition- The Commission did not follow the above criteria using CFP money; a contract was entered into, interviews conducted, however, the Davis Bacon Wage rates provided to the contractor were outdated, issued in 2010. In addition, no mention of fringe benefits was provided.
The Commission agrees with most of the finding; however, the wage rates were provided. We will update our procurement policy including the sections regarding the Davis Bacon prevailing wages.
CFDA 14.850 Public and Indian Housing Finding 2020-004 Governance and Board Actions Criteria- Uniform Guidance stresses the concept of Governance and Board involvement; however, do not condone micro-management or over-reaching. The Board is limited to following the Commission By-Laws, the state of Michigan Open Meetings Act, and other required Governmental Regulations. Condition- The Board hired an Executive Director and granted her authority to hire and terminate the staff, she reports directly to the Board of Directors. During the past year, the Board overturned a termination order and reinstated an employee.
Show full finding ▾Hide full finding ▴CFDA 14.850 Public and Indian Housing Finding 2020-004 Governance and Board Actions Criteria- Uniform Guidance stresses the concept of Governance and Board involvement; however, do not condone micro-management or over-reaching. The Board is limited to following the Commission By-Laws, the state of Michigan Open Meetings Act, and other required Governmental Regulations. Condition- The Board hired an Executive Director and granted her authority to hire and terminate the staff, she reports directly to the Board of Directors. During the past year, the Board overturned a termination order and reinstated an employee.
The Board accept the need to become more informed about HUD expectations relative to the board's role in staffing; and accept that if an exhaustive search for the by-laws is negative, that they be rewritten. However, disagree with over reaching or micro managing. We are considering hiring a third party to review termination of staff prior to taking action, but disagree that it is not our right to intervene in staffing issues.
2019-001
CFDA 14.871 Housing Assistance Program Finding 2020-005 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR?s address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- I reviewed 9 tenant files, the following discrepancies were noted: -3 of the 9 files did not have a current Housing Assistance Payments contract -5 of the 9 files did not have the correct Utility Allowance -some other files had missing required forms
Show full finding ▾Hide full finding ▴CFDA 14.871 Housing Assistance Program Finding 2020-005 Housing Assistance Program Discrepancies Criteria- Several PIH notices and CFR?s address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- I reviewed 9 tenant files, the following discrepancies were noted: -3 of the 9 files did not have a current Housing Assistance Payments contract -5 of the 9 files did not have the correct Utility Allowance -some other files had missing required forms
We plan on hiring an outside consulting firm to review the entire section 8 program and tenant files; in addition, the consultant can give recommendations so we will be in compliance.
2019-002
Finding 2020-006 Capital Projects Fund Program Discrepancies Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also required are a contract, insurance certificate naming the Commission as beneficiary in the event of non-completion and certified payrolls. Condition- The Commission did not follow the above criteria using CFP money; initially the contract was thought to be an emergency- therefore, could forgo the above requirements, however, the families were not required to leave the units, and the repairs lasted over 6 months. Emergencies are required to be resolved in 48 hours or the family relocated until the emergency is eliminated.
Show full finding ▾Hide full finding ▴Finding 2020-006 Capital Projects Fund Program Discrepancies Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also required are a contract, insurance certificate naming the Commission as beneficiary in the event of non-completion and certified payrolls. Condition- The Commission did not follow the above criteria using CFP money; initially the contract was thought to be an emergency- therefore, could forgo the above requirements, however, the families were not required to leave the units, and the repairs lasted over 6 months. Emergencies are required to be resolved in 48 hours or the family relocated until the emergency is eliminated.
We have hired an experienced Capital Fund Coordinator with greater knowledge of the Capital fund program; we anticipate the new hire will alleviate any further issues related to the Capital fund grant requirements.
2019-003
FAC accepted this audit on March 11, 2020 — management decision was due September 11, 2020.
Criteria- Uniform Guidance stresses the concept of Governance and Board involvement; however, do not condone micro-management or over-reaching. The Board is limited to following the Commission By-Laws, the State of Michigan Open Meetings Act, and other required Governmental Regulations. Condition- The Board hired an Executive Director and granted her authority to hire and terminate the staff; she reports directly to the Board of Directors. During the past year, the Board over turned a termination order and reinstated an employee.
Show full finding ▾Hide full finding ▴Criteria- Uniform Guidance stresses the concept of Governance and Board involvement; however, do not condone micro-management or over-reaching. The Board is limited to following the Commission By-Laws, the State of Michigan Open Meetings Act, and other required Governmental Regulations. Condition- The Board hired an Executive Director and granted her authority to hire and terminate the staff; she reports directly to the Board of Directors. During the past year, the Board over turned a termination order and reinstated an employee.
This response is based upon review of an audit recently provided to us with a cover dated June 30, 2019 and executive memorandum dated February 10, 2020. This letter responds to the assertion that you interpret some of the River Rouge Housing Commission's actions to be "over-reaching" or "micro- managing." On page #25 of your audit, you raise two allegations in support of your opinion: 1) The board's failure to follow commission by-laws, the State of Michigan Open Meetings Act, and other governmental regulations. 2) The director exclusively holds the authority for all staffing matters including hiring and firing. With respect to item #1, we are not in complete agreement with you, but accept that the board needs to become more informed about HUD expectations relative to the board's role in staffing; and accept that if an exhaustive search for the by-laws is negative, that they be rewritten. A cursory check of the State of Michigan Open Meetings Act and taking into consideration of how we conduct meetings does not suggest we are violating regulations. Moreover, our current knowledge base about HUD regulations and recollection about the commission's by-laws does not suggest any violations . Still, as stated, we are committed to obtaining training to learn more about HUD's expectations regarding our role as board members. - 2 6 - On item #2, we strongly disagree that the actions we took in the examples provided should be characterized as ?over-reaching? nor ?micro-managing.? Firstly, the issue of the board?s oversight of the housing director?s decisions to staff, especially firing must be viewed broadly. As far as we know, nothing provided the director with the exclusive authority to fire, nor restricted the board from making the final decision on terminations. The director?s 3-year contract does not expressly mention staffing, let alone authorizing her to make exclusive decisions on hiring and firing. (We believe such absolute authority would be unwise and impede our ability to provide the proper oversight and accountability). While we are unaware of documents that empower the director to exclusively decide on terminations, we do have access to at least one policy guideline that assert?s board input. The 66-page River Rouge Housing Commission Employee Handbook covers the rules by which the River Rouge Housing Commission (RRHC) controls the actions of its employees. On page #34 of the employee handbook it states that the ?Executive Director will discuss the employee?s misconduct with River Rouge Housing Commission Board of Commissioners. The River Rouge Housing Commission Board of Commissioners will make the final decision on the appropriateness of the discharge.? Given that each employee is supposed to be governed by and familiar with the employee handbook, part of due process would compel the board?s involvement. Secondly, we turn our discussion from broadly to the specific example raised. You asserted that ?the Board over turned a termination order and reinstated and employee.? However, to ?reinstate? a person, they must have been legitimately terminated. Based upon the unilateral decision by the director to ?terminate? the individual without the board?s knowledge and involvement, we did not regard this as a fait accompli. Additionally, we considered other factors resulting from a related preliminary probe into improper workplace behavior. More information will be provided upon request, but suffice it to say that our primary rationale for intervening in the decision was to protect the RRHC from litigation. The board merely required that the director provide just cause for the decision. When it was articulated by the director a few weeks later that the employee?s performance deteriorated to an intolerable level, the director?s decision was upheld. The board acted upon its retention of ?the right to change, modify, suspend, interpret or cancel in whole or in part any of the published or unpublished personnel policies or procedures of the River Rouge Housing Commission, without advance notice, in its sole discretion, without having to give cause or justification for consideration to any employee. Recognition of these rights and prerogatives of the River Rouge Housing Commission is a term and condition of employment and of continued employment? (page 3 of employee handbook). Admittedly, this was an uncomfortable experience for the director and the board. For this reason, we look forward to learning about how we may solicit the services of an intermediary such as a hearing officer or committee to review termination proposals before finalization. In conclusion, we have reviewed this finding and have provided information so that it may be viewed in the proper context. Thank you for your consideration.
Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- I reviewed 9 tenant files, the following discrepancies were noted: -3 of the 9 files did not have a current Housing Assistance Payments contract -5 of the 9 files did not have the correct Utility Allowance -some other files had missing required forms
Show full finding ▾Hide full finding ▴Criteria- Several PIH notices and CFR's address compliance requirements within the Housing Choice Voucher Program; many discrepancies were noted during the review of tenant files. Condition- I reviewed 9 tenant files, the following discrepancies were noted: -3 of the 9 files did not have a current Housing Assistance Payments contract -5 of the 9 files did not have the correct Utility Allowance -some other files had missing required forms
RIVER ROUGE HOUSING COMMISSION (RRHC) IS IN THE PROCESS OF HIRING A CONSULTANT TO REVIEW THE ENTORIE SECTION 8 PROGRAM FILE PORTFOLIA OT MAKE SURE THAT ALL REQUIRED PROGRAM DOCUMENTATION IS IN THE FILES; AS WELL AS; TO REVIEW FILES FOR ACCURACY. THE UTILITY ALLOWANCES WILL BE REVIEWED FOR EACH FILE FOR CORRECTNESS. RRHC HAS A POLICY THAT RECERTIFICATIONS BE STARTED 120 DAYS IN ADVANCE OF THE RECERTIFICATION. THE CONSULTANT WILL HELP DETERMINE IF THIS POLICY IS BEING ADHERED TO. ADDITIONALLY, THE CONSULTANT CAN MAKE RECOMMENDATIONS TO MAKE SURE THAT RRHC IS IN COMPLIANCE WITH THE ADMINISTRATIVE PLAN AND HUD PROGRAM RULES.
2018-001
Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also required are a contract, insurance certificate naming the Commission as beneficiary in the event of non-completion and certified payrolls. Condition- The Commission did not follow the above criteria using CFP money; initially the contract was thought to be an emergency- therefore, could forgo the above requirements, however, the families were not required to leave the units, and the repairs lasted over 6 months. Emergencies are required to be resolved in 48 hours or the family relocated until the emergency is eliminated.
Show full finding ▾Hide full finding ▴Criteria- The Commission entered into a contract and used Capital Fund (CFP) money to complete the project; the rules governing the Capital Fund Grant were not followed. The Capital Fund requires all bids contain Davis Bacon Wage rates; also required are a contract, insurance certificate naming the Commission as beneficiary in the event of non-completion and certified payrolls. Condition- The Commission did not follow the above criteria using CFP money; initially the contract was thought to be an emergency- therefore, could forgo the above requirements, however, the families were not required to leave the units, and the repairs lasted over 6 months. Emergencies are required to be resolved in 48 hours or the family relocated until the emergency is eliminated.
RRHC HAS HIRED A NEW CAPITAL FUND COORDINATOR WITH GREATER KNOWLEDGE OF PROPER PROCUREMENT ACTIVITIES. THE NEW CAPITAL FUND COORDINATOR HAS WORKED WITH PUBLIC HOUSING AGENCIES FOR A NUMBER OF YEARS AND IS MORE FAMILIAR WITH WHAT CONSTITUTES AS AN EMERGENCY AND HAS BETER KNOWLEDGE OF NECESSARY FILE DOCUMENTATION. THUIS NEW HIRE SHOULD ALLEVIATE ANY FURTHER ISSUES RELATED TO THE CAPITAL FUND GRANT REQUIREMENTS.
2018-002
FAC accepted this audit on January 19, 2019 — management decision was due July 19, 2019.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on December 21, 2017 — management decision was due June 21, 2018.
FAC accepted this audit on December 4, 2016 — management decision was due June 4, 2017.
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