Questioned Cost $-
Finding No. 2023‐005: Suspension and Debarment (Significant Deficiency)
State Agency: Department of Land and Natural Resources (“DLNR”)
Federal Agency: Department of Interior
AL Number and Title: 15.615 – Cooperative Endangered Species Conservation Fund
Award Number and Award Year: F22AP03217 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether any of the contractors were federally suspended or debarred.
Criteria
According to 2 CFR 200.214, regulations restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from, ineligible from, or ineligible for participation in federal assistance programs or activities. Therefore, verification is required by checking the System for Award Management (SAM), an official website for the U.S. Government, obtaining a certification from the contractor, or adding a clause or condition to the contract.
Effect
Without evaluating the contractors’ status on the SAM before executing agreements, the State may contract with suspended or debarred entities.
Cause and View of Responsible Officials
Program personnel responsible for procurement indicated that a review for the federal SAM website was performed prior to the execution of the contract, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of the suspension and debarment review, including who performed the procedure and the date performed, prior to entering into the agreement.
Questioned Cost $-
Finding No. 2023‐006: Reporting (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.615 – Cooperative Endangered Species Conservation Fund
Award Number and Award Year: F22AP03217 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of one subaward and found that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the Federal Funding Accountability and Transparency Act (“FFATA”) was not completed timely.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to file the report in a timely manner.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐007: Suspension and Debarment (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.634 – State Wildlife Grants (R&D Cluster)
Award Number and Award Year: F21AP00578 F22AP03438 2022 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether the contractors were federally suspended or debarred.
Criteria
According to 2 CFR 200.214, regulations restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from, ineligible from, or ineligible for participation in federal assistance programs or activities. Therefore, verification is required by checking the SAM, an official website for the U.S. Government, obtaining a certification from the contractor, or adding a clause or condition to the contract.
Effect
Without evaluating the contractors’ status on the SAM before executing agreements, the State may contract with suspended or debarred entities.
Cause and View of Responsible Officials
Program personnel responsible for procurement indicated that a review for the federal SAM website was performed prior to the execution of the contract, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of the suspension and debarment review, including who performed the procedure and the date performed, prior to entering into the agreement.
Questioned Cost $-
Finding No. 2023‐008: Subrecipient Monitoring (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.634 – State Wildlife Grants (R&D Cluster)
Award Number and Award Year: F21AP00578 F22AP03438 2022 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of two subawards and noted the following instances of noncompliance:
-Subaward agreements did not include certain required federal award information.
-No evidence of pass‐through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F.
Criteria
2 CFR Section 200.332(a) requires subawards to clearly identify information, such as Federal Award Identification Number (FAIN), identification of whether the award is R&D, period of performance, and indirect costs.
2 CFR Section 200.332(f) requires a pass‐through entity to verify that every subrecipient is audited as required by 2 CFR Section 200, Subpart F, when it is expected that the subrecipient’s expenditures exceed applicable thresholds.
Effect
By not including the required information in the subaward and verifying whether the subrecipient is audited, the State may not be providing the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Program personnel responsible indicated that subaward information was provided and verification of audit was performed, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of process, including who performed the procedure and the date performed.
Questioned Cost $1,643
Finding No. 2023‐009: Eligibility (Significant Deficiency)
State Agency: Department of Labor and Industrial Relations ("DLIR")
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we selected a non‐statistical sample of sixty benefit payments made during the year and identified two payments where the recipients did not make the minimum number of work search contacts.
Criteria
Pursuant to State Handbook of Unemployment Benefits, the following requirements must be met to become eligible for benefit payments:
1) Be totally or partially unemployed;
2) File an application to establish an unemployment insurance claim;
3) File a claim certification on a weekly or bi‐weekly basis to request payment of benefits;
4) Register for work with the State Workforce Development Division;
5) Participate in re‐employment services;
6) Be physically and mentally able to work;
7) Be ready and willing to seek and accept work by making three or more work search contacts every week;
8) Serve a one‐week waiting period; and
9) Report for interviews.
Effect
Failure to comply with the eligibility requirements results in noncompliance with the terms of the award and may result in recapture of funds by the awarding agency.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to investigate cases within a timely manner.
Recommendation
We recommend that the State department follow the policies and procedures established to comply with eligibility requirements. Furthermore, we recommend that the department formalize any modifications to the work search requirements used in practice as allowed under HRS Section 12‐5‐34.
Questioned Cost $1,643
Finding No. 2023‐009: Eligibility (Significant Deficiency)
State Agency: Department of Labor and Industrial Relations ("DLIR")
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we selected a non‐statistical sample of sixty benefit payments made during the year and identified two payments where the recipients did not make the minimum number of work search contacts.
Criteria
Pursuant to State Handbook of Unemployment Benefits, the following requirements must be met to become eligible for benefit payments:
1) Be totally or partially unemployed;
2) File an application to establish an unemployment insurance claim;
3) File a claim certification on a weekly or bi‐weekly basis to request payment of benefits;
4) Register for work with the State Workforce Development Division;
5) Participate in re‐employment services;
6) Be physically and mentally able to work;
7) Be ready and willing to seek and accept work by making three or more work search contacts every week;
8) Serve a one‐week waiting period; and
9) Report for interviews.
Effect
Failure to comply with the eligibility requirements results in noncompliance with the terms of the award and may result in recapture of funds by the awarding agency.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to investigate cases within a timely manner.
Recommendation
We recommend that the State department follow the policies and procedures established to comply with eligibility requirements. Furthermore, we recommend that the department formalize any modifications to the work search requirements used in practice as allowed under HRS Section 12‐5‐34.
Questioned Cost $-
Finding No. 2023‐010: Special Tests and Provisions (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we examined the Benefit Accuracy Measurement (BAM) summary report and identified that minimum cases and timeliness requirements were not met for paid and denied claims.
Criteria
Pursuant to 20 CFR Part 602, the BAM system requires the State department to complete a minimum number of unemployment cases timely in order to maintain a current database. The required number of cases and the timeliness percentages for completing paid and denied claims are as follows:
Paid Claims
-Minimum cases: 480 paid cases
-Timeliness percentages: Complete 70% within 60 days, 95% within 90 days, and 98% within 120 days
Denied Claims
-Minimum cases: 450 denied cases (150 cases for each category: monetary, separation and non‐separation)
-Timeliness percentages: Complete 60% within 60 days, 85% within 90 days, and 98% within 120 days
Effect
Failure to meet timeliness requirements prevents the granting agency from maintaining a current database.
Cause and View of Responsible Officials
Due to the COVID‐19 pandemic, the department experienced a staffing shortage and was unable to process the minimum number of cases and/or investigate cases within a timely manner.
Recommendation
We recommend that the State department address staffing shortages and develop new policies and procedures to handle the increase in unemployment claims and follow existing policies and procedures established to comply with claim handling requirements, as necessary.
Questioned Cost $-
Finding No. 2023‐010: Special Tests and Provisions (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we examined the Benefit Accuracy Measurement (BAM) summary report and identified that minimum cases and timeliness requirements were not met for paid and denied claims.
Criteria
Pursuant to 20 CFR Part 602, the BAM system requires the State department to complete a minimum number of unemployment cases timely in order to maintain a current database. The required number of cases and the timeliness percentages for completing paid and denied claims are as follows:
Paid Claims
-Minimum cases: 480 paid cases
-Timeliness percentages: Complete 70% within 60 days, 95% within 90 days, and 98% within 120 days
Denied Claims
-Minimum cases: 450 denied cases (150 cases for each category: monetary, separation and non‐separation)
-Timeliness percentages: Complete 60% within 60 days, 85% within 90 days, and 98% within 120 days
Effect
Failure to meet timeliness requirements prevents the granting agency from maintaining a current database.
Cause and View of Responsible Officials
Due to the COVID‐19 pandemic, the department experienced a staffing shortage and was unable to process the minimum number of cases and/or investigate cases within a timely manner.
Recommendation
We recommend that the State department address staffing shortages and develop new policies and procedures to handle the increase in unemployment claims and follow existing policies and procedures established to comply with claim handling requirements, as necessary.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐014: Reporting (Significant Deficiency)
State Agency: Department of Defense
Federal Agency: Department of Homeland Security
AL Number and Title: 97.067 – Homeland Security Grant Program
Award Number and Award Year: EMW‐2022‐SS‐0036 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of three subawards and found that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA were not filed timely.
[TABLE]
Critera
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports timely reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐005: Suspension and Debarment (Significant Deficiency)
State Agency: Department of Land and Natural Resources (“DLNR”)
Federal Agency: Department of Interior
AL Number and Title: 15.615 – Cooperative Endangered Species Conservation Fund
Award Number and Award Year: F22AP03217 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether any of the contractors were federally suspended or debarred.
Criteria
According to 2 CFR 200.214, regulations restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from, ineligible from, or ineligible for participation in federal assistance programs or activities. Therefore, verification is required by checking the System for Award Management (SAM), an official website for the U.S. Government, obtaining a certification from the contractor, or adding a clause or condition to the contract.
Effect
Without evaluating the contractors’ status on the SAM before executing agreements, the State may contract with suspended or debarred entities.
Cause and View of Responsible Officials
Program personnel responsible for procurement indicated that a review for the federal SAM website was performed prior to the execution of the contract, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of the suspension and debarment review, including who performed the procedure and the date performed, prior to entering into the agreement.
Questioned Cost $-
Finding No. 2023‐006: Reporting (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.615 – Cooperative Endangered Species Conservation Fund
Award Number and Award Year: F22AP03217 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of one subaward and found that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the Federal Funding Accountability and Transparency Act (“FFATA”) was not completed timely.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to file the report in a timely manner.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐007: Suspension and Debarment (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.634 – State Wildlife Grants (R&D Cluster)
Award Number and Award Year: F21AP00578 F22AP03438 2022 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether the contractors were federally suspended or debarred.
Criteria
According to 2 CFR 200.214, regulations restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from, ineligible from, or ineligible for participation in federal assistance programs or activities. Therefore, verification is required by checking the SAM, an official website for the U.S. Government, obtaining a certification from the contractor, or adding a clause or condition to the contract.
Effect
Without evaluating the contractors’ status on the SAM before executing agreements, the State may contract with suspended or debarred entities.
Cause and View of Responsible Officials
Program personnel responsible for procurement indicated that a review for the federal SAM website was performed prior to the execution of the contract, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of the suspension and debarment review, including who performed the procedure and the date performed, prior to entering into the agreement.
Questioned Cost $-
Finding No. 2023‐008: Subrecipient Monitoring (Significant Deficiency)
State Agency: DLNR
Federal Agency: Department of Interior
AL Number and Title: 15.634 – State Wildlife Grants (R&D Cluster)
Award Number and Award Year: F21AP00578 F22AP03438 2022 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of two subawards and noted the following instances of noncompliance:
-Subaward agreements did not include certain required federal award information.
-No evidence of pass‐through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F.
Criteria
2 CFR Section 200.332(a) requires subawards to clearly identify information, such as Federal Award Identification Number (FAIN), identification of whether the award is R&D, period of performance, and indirect costs.
2 CFR Section 200.332(f) requires a pass‐through entity to verify that every subrecipient is audited as required by 2 CFR Section 200, Subpart F, when it is expected that the subrecipient’s expenditures exceed applicable thresholds.
Effect
By not including the required information in the subaward and verifying whether the subrecipient is audited, the State may not be providing the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Program personnel responsible indicated that subaward information was provided and verification of audit was performed, however, no formal documentation of the review was retained.
Recommendation
We recommend that program management retain evidence of process, including who performed the procedure and the date performed.
Questioned Cost $1,643
Finding No. 2023‐009: Eligibility (Significant Deficiency)
State Agency: Department of Labor and Industrial Relations ("DLIR")
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we selected a non‐statistical sample of sixty benefit payments made during the year and identified two payments where the recipients did not make the minimum number of work search contacts.
Criteria
Pursuant to State Handbook of Unemployment Benefits, the following requirements must be met to become eligible for benefit payments:
1) Be totally or partially unemployed;
2) File an application to establish an unemployment insurance claim;
3) File a claim certification on a weekly or bi‐weekly basis to request payment of benefits;
4) Register for work with the State Workforce Development Division;
5) Participate in re‐employment services;
6) Be physically and mentally able to work;
7) Be ready and willing to seek and accept work by making three or more work search contacts every week;
8) Serve a one‐week waiting period; and
9) Report for interviews.
Effect
Failure to comply with the eligibility requirements results in noncompliance with the terms of the award and may result in recapture of funds by the awarding agency.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to investigate cases within a timely manner.
Recommendation
We recommend that the State department follow the policies and procedures established to comply with eligibility requirements. Furthermore, we recommend that the department formalize any modifications to the work search requirements used in practice as allowed under HRS Section 12‐5‐34.
Questioned Cost $1,643
Finding No. 2023‐009: Eligibility (Significant Deficiency)
State Agency: Department of Labor and Industrial Relations ("DLIR")
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we selected a non‐statistical sample of sixty benefit payments made during the year and identified two payments where the recipients did not make the minimum number of work search contacts.
Criteria
Pursuant to State Handbook of Unemployment Benefits, the following requirements must be met to become eligible for benefit payments:
1) Be totally or partially unemployed;
2) File an application to establish an unemployment insurance claim;
3) File a claim certification on a weekly or bi‐weekly basis to request payment of benefits;
4) Register for work with the State Workforce Development Division;
5) Participate in re‐employment services;
6) Be physically and mentally able to work;
7) Be ready and willing to seek and accept work by making three or more work search contacts every week;
8) Serve a one‐week waiting period; and
9) Report for interviews.
Effect
Failure to comply with the eligibility requirements results in noncompliance with the terms of the award and may result in recapture of funds by the awarding agency.
Cause and View of Responsible Officials
The department experienced a staffing shortage and was unable to investigate cases within a timely manner.
Recommendation
We recommend that the State department follow the policies and procedures established to comply with eligibility requirements. Furthermore, we recommend that the department formalize any modifications to the work search requirements used in practice as allowed under HRS Section 12‐5‐34.
Questioned Cost $-
Finding No. 2023‐010: Special Tests and Provisions (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we examined the Benefit Accuracy Measurement (BAM) summary report and identified that minimum cases and timeliness requirements were not met for paid and denied claims.
Criteria
Pursuant to 20 CFR Part 602, the BAM system requires the State department to complete a minimum number of unemployment cases timely in order to maintain a current database. The required number of cases and the timeliness percentages for completing paid and denied claims are as follows:
Paid Claims
-Minimum cases: 480 paid cases
-Timeliness percentages: Complete 70% within 60 days, 95% within 90 days, and 98% within 120 days
Denied Claims
-Minimum cases: 450 denied cases (150 cases for each category: monetary, separation and non‐separation)
-Timeliness percentages: Complete 60% within 60 days, 85% within 90 days, and 98% within 120 days
Effect
Failure to meet timeliness requirements prevents the granting agency from maintaining a current database.
Cause and View of Responsible Officials
Due to the COVID‐19 pandemic, the department experienced a staffing shortage and was unable to process the minimum number of cases and/or investigate cases within a timely manner.
Recommendation
We recommend that the State department address staffing shortages and develop new policies and procedures to handle the increase in unemployment claims and follow existing policies and procedures established to comply with claim handling requirements, as necessary.
Questioned Cost $-
Finding No. 2023‐010: Special Tests and Provisions (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.225 – Unemployment Insurance
COVID‐19 – 17.225 – COVID‐19 – Unemployment Insurance
Award Number and Award Year: UI‐39318‐23‐55‐A‐15 2023
Repeat Finding? Yes
Condition
During our audit, we examined the Benefit Accuracy Measurement (BAM) summary report and identified that minimum cases and timeliness requirements were not met for paid and denied claims.
Criteria
Pursuant to 20 CFR Part 602, the BAM system requires the State department to complete a minimum number of unemployment cases timely in order to maintain a current database. The required number of cases and the timeliness percentages for completing paid and denied claims are as follows:
Paid Claims
-Minimum cases: 480 paid cases
-Timeliness percentages: Complete 70% within 60 days, 95% within 90 days, and 98% within 120 days
Denied Claims
-Minimum cases: 450 denied cases (150 cases for each category: monetary, separation and non‐separation)
-Timeliness percentages: Complete 60% within 60 days, 85% within 90 days, and 98% within 120 days
Effect
Failure to meet timeliness requirements prevents the granting agency from maintaining a current database.
Cause and View of Responsible Officials
Due to the COVID‐19 pandemic, the department experienced a staffing shortage and was unable to process the minimum number of cases and/or investigate cases within a timely manner.
Recommendation
We recommend that the State department address staffing shortages and develop new policies and procedures to handle the increase in unemployment claims and follow existing policies and procedures established to comply with claim handling requirements, as necessary.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐011: Earmarking (Significant Deficiency)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐33225‐15‐55A‐15 2019
Repeat Finding? No
Condition
During our audit, we noted the following instances of noncompliance:
-A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers.
-A total of 74.60% of funds were allocated for services to out of school youth.
Criteria
According to Section 129(b) of the Workforce Innovation and Opportunity Act, not more than 15% of funds allocated shall be used to provide employment and training activities for adults and dislocated workers.
According to Section 129(c) of the Workforce Innovation and Opportunity Act, not less than 75% of funds allocated to the local area, except for local area administrative costs, shall be used to provide out of school youth.
Effect
Failure to comply with the award’s earmarking requirements results in noncompliance with the terms of the award and could result in sanctions by the awarding agency.
Cause and View of Responsible Officials
When the initial award is provided to the various subrecipients, program personnel allocate amounts in accordance with earmarking requirements. However, as actual results differ from the budget, program personnel became aware of noncompliance at the close of the award.
Recommendation
We recommend that program management establish policies and procedures with subrecipients to ensure earmarking requirements are met.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐012: Reporting (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of two subawards and found no evidence that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was completed.
[TABLE]
Criteria
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐013: Subrecipient Monitoring (Material Weakness)
State Agency: DLIR
Federal Agency: Department of Labor
AL Number and Title: 17.258 – WIOA Adult Program
17.259 – WIOA Youth Activities
17.278 – WIOA Dislocated Worker Formula Grant
(WIOA Cluster)
Award Number and Award Year: AA‐38525‐22‐55‐A‐15 2022
Repeat Finding? No
Condition
During our audit, we examined a non‐statistical sample of three subawards and noted the following instances of noncompliance:
-No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards.
-No evidence of on‐site monitoring procedures of the subrecipients.
Criteria
2 CFR Section 200.332(b) requires a pass‐through entity to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward.
2 CFR Section 200.332(d) requires a pass‐through entity to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in accordance with federal statutes and regulations.
Effect
Without evaluating the subrecipient’s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not provide the appropriate level of monitoring over its subrecipients.
Cause and View of Responsible Officials
Due to resource constraints, program personnel were unable to perform the subrecipient’s risk of noncompliance and on‐going monitoring procedures.
Recommendation
We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department’s responsibilities as a pass‐through entity are fulfilled, including a formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following:
-The subrecipient’s prior experience with the same or similar subawards;
-The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program;
-Whether the subrecipient has new personnel or new or substantially changed systems; and
-The extent and results of federal awarding agency monitoring
Questioned Cost $-
Finding No. 2023‐014: Reporting (Significant Deficiency)
State Agency: Department of Defense
Federal Agency: Department of Homeland Security
AL Number and Title: 97.067 – Homeland Security Grant Program
Award Number and Award Year: EMW‐2022‐SS‐0036 2022
Repeat Finding? No
Condition
During our audit, we tested a non‐statistical sample of three subawards and found that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA were not filed timely.
[TABLE]
Critera
Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA requires an entity to report subcontracts made under federally‐awarded contracts by the end of the month following the month in which the prime recipient awards any subgrant greater than or equal to $30,000.
Effect
Failure to file required reports timely reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 200.
Cause and View of Responsible Officials
Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports.
Recommendation
We recommend that program personnel ensure that required FFATA reports are filed timely.