Audit 340882

Finding 2023-003 – Reporting Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Federal Funding Accountability and Transparency Act (FFATA) (as codified in 2 CFR parts 170) requires direct recipients of grants and cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: The Organization did not comply with FFATA reporting requirements. Questioned Costs: Unknown Cause: The Organization does not have formal policies in place to identify subawards that require reporting in the FSRS as required under FFATA. Effect: The Organization was not in compliance with reporting requirements under FFATA. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure all required reporting is completed. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.

Finding 2023-004 – Subrecipient Monitoring Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Pass-through entities are required to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients are notified of their requirement to receive an audit and take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients and 2 CFR section 200.332(a) required pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN and amount that was paid during the year. Condition: The Organization did not comply with subrecipient monitoring requirements around risk assessment monitoring, audit requirement language, including federal assistance listing number, within their contract, and review of subrecipient single audit compliance. Questioned Costs: Unknown Cause: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure subrecipient monitoring includes proper risk assessment and monitoring of single audit compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.

Finding 2023-003 – Reporting Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Federal Funding Accountability and Transparency Act (FFATA) (as codified in 2 CFR parts 170) requires direct recipients of grants and cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: The Organization did not comply with FFATA reporting requirements. Questioned Costs: Unknown Cause: The Organization does not have formal policies in place to identify subawards that require reporting in the FSRS as required under FFATA. Effect: The Organization was not in compliance with reporting requirements under FFATA. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure all required reporting is completed. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.

Finding 2023-004 – Subrecipient Monitoring Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Pass-through entities are required to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients are notified of their requirement to receive an audit and take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients and 2 CFR section 200.332(a) required pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN and amount that was paid during the year. Condition: The Organization did not comply with subrecipient monitoring requirements around risk assessment monitoring, audit requirement language, including federal assistance listing number, within their contract, and review of subrecipient single audit compliance. Questioned Costs: Unknown Cause: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure subrecipient monitoring includes proper risk assessment and monitoring of single audit compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.