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(CAB). CAB has instituted a process to identify The Michigan DOT subrecipients expending in excess of the expendi- Although it was not the subject of a full case ture threshold for federal awards identified in OMB study, the Michigan DOT's use of a comprehen- Circular A-133. Subrecipients so identified are no- sive, state-published audit guide can be considered tified of their audit obligation under OMB Circular A-133, including the requirement to submit a copy a best practice. In Michigan, audits are reviewed of their federal OMB Circular A-133 Single Audit for compliance with the state's published Audit Report within 9 months after the end of their fiscal Guide for Transportation Authorities. If an annual year. CAB obtains the subrecipient's federal Single audit cites an OMB Circular A-133 transit audit Audit Report and, where applicable findings are finding associated with funds in which the state is identified, CAB issues a management decision. The the pass-through entity, that audit finding is iden- management decision states whether or not the audit tified, tracked, and resolved in accordance with finding is sustained, the reasons for the decision, and an internal operating instruction (e.g., IDI 70206 any corrective actions expected of the subrecipient "Identification, Review and Follow up of Audit (e.g., to repay disallowed costs, make financial ad- Findings") that meets the mandates of OMB Circular justments, or take other specific action). A timetable A-133. If ineligible expenditures are identified that for follow-up is provided for situations in which the are not properly subtracted out as ineligible, the subrecipient has not completed corrective actions. proper subtraction is made and the transit agency The management decision is issued within is notified of it. 6 months after receipt of the subrecipient's audit Audits required under Michigan state law are report. CAB may perform a limited-scope audit to used to reconcile eligible expenses, which are used verify that corrective action has taken place. A time- to determine state operating assistance. The Michi- table for follow-up is provided in the management gan DOT's transit subrecipients are notified of any decision to cover situations in which the subrecipi- areas of noncompliance with the state audit require- ent has not completed corrective actions. ments and asked to correct them. If adequate corrective action has not taken place The topics covered in the Michigan DOT's Audit or if the subrecipient fails to submit an audit report Guide for Transportation Authorities are listed in in accordance with OMB Circular A-133, CAB no- Appendix C. An online copy of the complete audit tifies the Accounting Bureau to suspend payment on guidance can be found at the following webpage: future reimbursement claims submitted by the sub- http://www.michigan.gov/documents/treasury/ recipient until notified otherwise. Audit_Guide_202115_7.pdf. 19