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How to Prevent Common Audit or Monitoring Review Findings

How to Prevent Common Audit or Monitoring Review Findings. Michigan State Police Emergency Management and Homeland Security Division. Jackie Reese, Audit Unit Manager Richard Sheaffer, Auditor. Objectives. To discuss common findings To identify grant requirements To provide solutions.

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How to Prevent Common Audit or Monitoring Review Findings

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  1. How to Prevent Common Audit or Monitoring Review Findings Michigan State Police Emergency Management and Homeland Security Division Jackie Reese, Audit Unit Manager Richard Sheaffer, Auditor

  2. Objectives • To discuss common findings • To identify grant requirements • To provide solutions http://www.michigan.gov/emhsd

  3. Suspension and Debarment The Problem • The subrecipient has not verified suspension and debarment and/or has not maintained documentation of the verification for a proposed contractor or vendor for a contract greater than $25,000. And/or 2. The subrecipient has not verified suspension and debarment for a subaward. http://www.michigan.gov/emhsd

  4. Suspension and Debarment Requirements 1. OMB Circular A-133 Compliance Supplement, Part 3, Section I Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. http://www.whitehouse.gov/sites/default/files/omb/circulars/a133_compliance/2010/pt3.pdf 2. 44 CFR 13.35 Grantees and subgrantees must not make any award (subgrant or contract) to any party which is debarred or suspended or is otherwise excluded from or ineligible for participation in Federal assistance programs. http://www.access.gpo.gov/nara/cfr/waisidx_03/44cfr13_03.html http://www.michigan.gov/emhsd

  5. Suspension and Debarment Solutions 1. Excluded Parties List System (EPLS) https://www.epls.gov/ Maintained by the General Services Administration (GSA) on parties that are excluded from receiving Federal contracts, certain subcontracts, and certain Federal financial and nonfinancial assistance and benefits. a. Go to website b. Enter search on proposed vendor or contractor c. Make a screen print of results and maintain in procurement file http://www.michigan.gov/emhsd

  6. Suspension and Debarment Solutions 2. Collecting a certification from the entity that they are not suspended or debarred. 3. Adding a clause or condition in the contract with that entity regarding suspension and debarment. http://www.michigan.gov/emhsd

  7. Equipment Inventory The Problem The subrecipient is not maintaining adequate property records and/or has not conducted and documented a physical inventory of equipment within the past two years. http://www.michigan.gov/emhsd

  8. Equipment Inventory Requirements 1. OMB Circular A-133 Compliance Supplement, Part 3, Section F http://www.whitehouse.gov/sites/default/files/omb/circulars/a133_compliance/2010/pt3.pdf 2. 44 CFR 13.32 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=44:1.0.1.1.14.3.13.10&idno=44 3. EMHSD a. Grant Agreement – Send a copy of the equipment inventory to Audit Unit. b. Individual Letter – Special request for equipment inventory to Audit Unit. http://www.michigan.gov/emhsd

  9. Equipment Inventory The Solution 1. Maintain an equipment inventory in compliance with 44 CFR 13.32 d. a. Use your own inventory documentation as long as it includes all elements of 44 CFR 13.32 b. Use EMHSD equipment tracking sheet http://michigan.gov/documents/msp/Equipment_Tracking_Form_317940_7.xls 2. Perform a physical inventory at least every 2 years and maintain documentation. http://www.michigan.gov/emhsd

  10. Subrecipient Monitoring The Problem The Subrecipient has not ensured that subrecipients expending $500,000 or more in Federal awards have met the audit requirements of OMB Circular A-133. http://www.michigan.gov/emhsd

  11. Subrecipient Monitoring The Requirement OMB Circular A-133 Section 400 (d) Identifies pass-through entity responsibilities including: Identify Federal awards; advise of rules and regulations; monitor activities; ensure subrecipients meet audit requirements; issue management decision; consider adjustment of records; and ensure access to records. http://www.whitehouse.gov/sites/default/files/omb/assets/a133/a133_revised_2007.pdf http://www.michigan.gov/emhsd

  12. Subrecipient Monitoring The Solution 1. Determine if pass-through entity is required to have a single audit. 2. Collect and review single audit report according to OMB Circular A-133. a. May use EMHSD Job Aid- Sample Subrecipient Single Audit Review Form. b. May use own review method in compliance with OMB Circular A-133. 3. Issue management decision and request corrective action for findings related to award. 4. Document review. http://www.michigan.gov/emhsd

  13. Training and Exercise Attendance Records The Problem The subrecipient does not maintain sufficient attendance records to support training and exercise activity. http://www.michigan.gov/emhsd

  14. Training and ExerciseAttendance Records The Requirement 44 CFR 13.20 (a) (6) Source documentation. Accounting records must be supported by such source documentation as cancelled checks, paid bills, payrolls, time and attendance records, contract and subgrant award documents, etc.http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=1c5af50a8ac9e8c026b91e0a17e21b16&rgn=div8&view=text&node=44:1.0.1.1.14.3.12.1&idno=44 http://www.michigan.gov/emhsd

  15. Training and ExerciseAttendance Records The Solution Maintain an attendance record of training and exercise activity. Documentation should include: 1. Course Name 2. Date 3. Participant’s name 4. Sign-in sheet http://www.michigan.gov/emhsd

  16. Support for Salaries and Wages The Problem The subrecipient does not maintain sufficient supporting documentation for salaries and wages charged to the grant. http://www.michigan.gov/emhsd

  17. Support for Salaries and Wages The Requirements 1. 2 CFR 225, Attachment B (8) (h) (3) Time Certification - Employees working on a single Federal award will be supported by a certification (at least semi-annually). 2. 2 CFR 225, Attachment B (8) (h) (4) Activity Report – Employees working on multiple activities will be supported by an activity report. (2 CFR 225 formerly OMB Circular A-87) http://www.whitehouse.gov/sites/default/files/omb/fedreg/2005/083105_a87.pdf http://www.michigan.gov/emhsd

  18. Support for Salaries and Wages The Solution 1. For employees working on a single Federal award, sign time certifications at least semi-annually. 2. For employees working on multiple activities, prepare personnel activity reports. http://www.michigan.gov/emhsd

  19. Questions http://www.michigan.gov/emhsd

  20. Contact Information Richard Sheaffer, Auditor Jackie Reese, Audit Unit Manager Phone: (517) 333-4624 Phone: (517) 324-2330 Email: sheaffrp@michigan.gov Email: reesej@michigan.gov http://www.michigan.gov/emhsd

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