Audit 351526

Finding 2024-002: Subrecipient Monitoring - Risk Assessment Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Finding 2024-003: Reporting Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) Support Foundation did not comply with FFATA reporting requirements. Effect: Failure to comply with the FFATA requirement may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Finding 2024-004: Identifying the Award and Applicable Requirements Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: As codified in 2 CFR Part 200.332, requires prime awardees awarded a federal grant to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the pass-through entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award. Condition: We tested subrecipient awards and found that there were no official subrecipient grant letters identifying the award and its applicable requirements. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) identifying the award and applicable requirements and described in 2 CFR section 200.332 Effect: Failure to comply with the 2 CFR section 200.332 requirements may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its procedures to provide subrecipients with official grant letters that include the requirements under 2 CFR section 200.332. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Finding 2024-002: Subrecipient Monitoring - Risk Assessment Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Finding 2024-003: Reporting Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) Support Foundation did not comply with FFATA reporting requirements. Effect: Failure to comply with the FFATA requirement may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Finding 2024-004: Identifying the Award and Applicable Requirements Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: As codified in 2 CFR Part 200.332, requires prime awardees awarded a federal grant to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the pass-through entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award. Condition: We tested subrecipient awards and found that there were no official subrecipient grant letters identifying the award and its applicable requirements. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) identifying the award and applicable requirements and described in 2 CFR section 200.332 Effect: Failure to comply with the 2 CFR section 200.332 requirements may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its procedures to provide subrecipients with official grant letters that include the requirements under 2 CFR section 200.332. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan