Subrecipient Monitoring
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Number: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Period: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR section 200.332 states that once a pass-through entity has made the decision between subrecipient versus contractor determination, the pass-through entity 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 performance goals are achieved.
Condition: The County did not follow their established controls related to ensuring subrecipient monitoring policies were followed.
Questioned Costs: $300,000
Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with subrecipient monitoring requirements.
Cause: While the County's grant administration policy discusses the steps needed to monitor subrecipients, the County did not have a designated individual to follow up on the monitoring of the subrecipient to ensure compliance.
Effect: The County is not in compliance with subrecipient monitoring requirements. Grant funding received by a subrecipient could be used in a manner that is not compliant with Uniform Guidance.
Repeat Finding: No
Recommendation: We recommend the County review internal policies and procedures regarding who is responsible for monitoring the subrecipient in order to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants.
View of Responsible Officials: There is no disagreement with the finding.
Suspension & Debarment
Federal Agency: U.S. Department of Treasury
Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Numbers: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Numbers: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Periods: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment.
Questioned Costs: None.
Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred.
Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures.
Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance.
Repeat Finding: Yes; 2022-003
Subrecipient Monitoring
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Number: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Period: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR section 200.332 states that once a pass-through entity has made the decision between subrecipient versus contractor determination, the pass-through entity 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 performance goals are achieved.
Condition: The County did not follow their established controls related to ensuring subrecipient monitoring policies were followed.
Questioned Costs: $300,000
Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with subrecipient monitoring requirements.
Cause: While the County's grant administration policy discusses the steps needed to monitor subrecipients, the County did not have a designated individual to follow up on the monitoring of the subrecipient to ensure compliance.
Effect: The County is not in compliance with subrecipient monitoring requirements. Grant funding received by a subrecipient could be used in a manner that is not compliant with Uniform Guidance.
Repeat Finding: No
Recommendation: We recommend the County review internal policies and procedures regarding who is responsible for monitoring the subrecipient in order to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants.
View of Responsible Officials: There is no disagreement with the finding.
Suspension & Debarment
Federal Agency: U.S. Department of Treasury
Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Numbers: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Numbers: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Periods: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment.
Questioned Costs: None.
Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred.
Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures.
Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance.
Repeat Finding: Yes; 2022-003
Subrecipient Monitoring
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Number: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Period: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR section 200.332 states that once a pass-through entity has made the decision between subrecipient versus contractor determination, the pass-through entity 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 performance goals are achieved.
Condition: The County did not follow their established controls related to ensuring subrecipient monitoring policies were followed.
Questioned Costs: $300,000
Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with subrecipient monitoring requirements.
Cause: While the County's grant administration policy discusses the steps needed to monitor subrecipients, the County did not have a designated individual to follow up on the monitoring of the subrecipient to ensure compliance.
Effect: The County is not in compliance with subrecipient monitoring requirements. Grant funding received by a subrecipient could be used in a manner that is not compliant with Uniform Guidance.
Repeat Finding: No
Recommendation: We recommend the County review internal policies and procedures regarding who is responsible for monitoring the subrecipient in order to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants.
View of Responsible Officials: There is no disagreement with the finding.
Suspension & Debarment
Federal Agency: U.S. Department of Treasury
Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Numbers: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Numbers: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Periods: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment.
Questioned Costs: None.
Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred.
Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures.
Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance.
Repeat Finding: Yes; 2022-003
Subrecipient Monitoring
Federal Agency: U.S. Department of Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Number: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Period: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR section 200.332 states that once a pass-through entity has made the decision between subrecipient versus contractor determination, the pass-through entity 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 performance goals are achieved.
Condition: The County did not follow their established controls related to ensuring subrecipient monitoring policies were followed.
Questioned Costs: $300,000
Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with subrecipient monitoring requirements.
Cause: While the County's grant administration policy discusses the steps needed to monitor subrecipients, the County did not have a designated individual to follow up on the monitoring of the subrecipient to ensure compliance.
Effect: The County is not in compliance with subrecipient monitoring requirements. Grant funding received by a subrecipient could be used in a manner that is not compliant with Uniform Guidance.
Repeat Finding: No
Recommendation: We recommend the County review internal policies and procedures regarding who is responsible for monitoring the subrecipient in order to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants.
View of Responsible Officials: There is no disagreement with the finding.
Suspension & Debarment
Federal Agency: U.S. Department of Treasury
Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Numbers: 21.027
Pass-Through Agency: Wisconsin Department of Health Services
Pass-Through Numbers: 155811
Federal Award Identification Number and Year: SLFRP0756; 2020
Award Periods: March 1, 2020 – December 31, 2024
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment.
Questioned Costs: None.
Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred.
Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures.
Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance.
Repeat Finding: Yes; 2022-003