Audit 304116

Criteria: CFR 200.332(d) states: All pass-through entities must… monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particulate subaward. (3) Issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 200.513(a)(3)(vii). Such reliance does not conform to the agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Condition: The County did not perform subrecipient monitoring of a school district that received the subaward. Cause: The County was not aware of the requirement to monitor the subrecipient. Effect: Unallowed activities could be undertaken or unallowed costs could be claimed under the program. Questioned Costs: None Perspective: Amounts passed through to subrecipients for the year totaled $2,042,606, of which $1,400,000 was passed through to the Sheridan School District which is subject to its own separate audit under the Uniform Guidance. Views of Officials: The County agrees with the findings and will develop a corrective action plan to implement to have all future grant recipients, regardless of whether they are administered by a third party partner or a non-competitive discretionary allocation, be required to register their organization on the County's online portal.

Criteria: CFR 200.332(d) states: All pass-through entities must… monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particulate subaward. (3) Issuing a management decision for applicable audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section 200.513(a)(3)(vii). Such reliance does not conform to the agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Condition: The County did not perform subrecipient monitoring of a school district that received the subaward. Cause: The County was not aware of the requirement to monitor the subrecipient. Effect: Unallowed activities could be undertaken or unallowed costs could be claimed under the program. Questioned Costs: None Perspective: Amounts passed through to subrecipients for the year totaled $2,042,606, of which $1,400,000 was passed through to the Sheridan School District which is subject to its own separate audit under the Uniform Guidance. Views of Officials: The County agrees with the findings and will develop a corrective action plan to implement to have all future grant recipients, regardless of whether they are administered by a third party partner or a non-competitive discretionary allocation, be required to register their organization on the County's online portal.