FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003)
Federal Program: McKinney Education for Homeless Children
Project No: 22-4920-00 and 23-4920-00
Federal Assistance
Listing Number: 84.196A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
AND
Federal Program: COVID-19 ARP – McKinney Education for Homeless Children
Project No: 22-4998-HM
Federal Assistance
Listing Number: 84.425W
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure the process to monitor subrecipients of federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47:
• Did not identify the subaward and applicable requirements in the agreements.
• Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward.
• Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023.
• Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single
audit.
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $939,424 of federal awards in fiscal year 2023. The Regional Office of Education #47 passed-through a total of $221,851 of federal awards in fiscal year 2023 of which $144,703 was funded by McKinney Education for Homeless Children and $77,148 by COVID-19 ARP – McKinney Education for Homeless Children grants.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47’s internal control system does not include controls to properly detect and prevent noncompliance with subrecipient monitoring requirements in a timely manner.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Identifying the subaward and applicable requirements in the agreements;
b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
c. Utilizing risk assessment results to develop and implement necessary subrecipient monitoring procedures for
the fiscal year;
d. Conducting subrecipient monitoring procedures; and
e. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.