Audit 335464

U.S. Department of Health and Human Services Family Planning Services AL #93.217 Award No. FPHPA006563, FPHPA006619 Criteria: 2 CFR 200.331 requires that pass‐through entities disbursing federal funds to subrecipients have a formalized policy for identifying the subrecipient meets the applicable requirements, for evaluating risk, for monitoring subrecipient activity, and for ensuring accountability of For‐Profit Subrecipients, if applicable. Additionally, certain information regarding the federal award is required to be communicated to the subrecipient. During monitoring activities, the pass‐through entity is required to obtain the subrecipient’s audit reports so any findings can be evaluated by the pass‐through entity’s management. Condition: The Organization does not have a formalized policy. Additionally, the subrecipient agreements were missing required information and audit report findings were not reviewed and followed‐up on. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Certain compliance elements related to subrecipient monitoring were not met as a result of ineffective controls. Questioned Costs: None Context/Sampling: There were 11 subrecipients during the year, of which 3 were selected for review. Repeat Finding from Prior Year: No Recommendation: Management should implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332 and update the subrecipient agreements to include all required information. Additionally, audit findings should be followed up on. Views of Responsible Officials: Management agrees with this finding.

U.S. Department of Health and Human Services Family Planning Services AL #93.217 Award No. FPHPA006563, FPHPA006619 Criteria: 2 CFR 200.331 requires that pass‐through entities disbursing federal funds to subrecipients have a formalized policy for identifying the subrecipient meets the applicable requirements, for evaluating risk, for monitoring subrecipient activity, and for ensuring accountability of For‐Profit Subrecipients, if applicable. Additionally, certain information regarding the federal award is required to be communicated to the subrecipient. During monitoring activities, the pass‐through entity is required to obtain the subrecipient’s audit reports so any findings can be evaluated by the pass‐through entity’s management. Condition: The Organization does not have a formalized policy. Additionally, the subrecipient agreements were missing required information and audit report findings were not reviewed and followed‐up on. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Certain compliance elements related to subrecipient monitoring were not met as a result of ineffective controls. Questioned Costs: None Context/Sampling: There were 11 subrecipients during the year, of which 3 were selected for review. Repeat Finding from Prior Year: No Recommendation: Management should implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332 and update the subrecipient agreements to include all required information. Additionally, audit findings should be followed up on. Views of Responsible Officials: Management agrees with this finding.