Audit 366192

Significant deficiency in internal controls over subrecipient monitoring. • Program Title: Substance Abuse Block Grants • Assistance Listing Number: 93.959 • Federal award identification number: B08TI085843 • Federal Agency: Department of Health and Human Services • Pass-through Entity: Washington State Health Care Authority Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.332 requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward. Condition/Context Washington Association of Sheriffs & Police Chiefs (the Association) passes substantially all federal funding through to subrecipients. During testing it was identified that, although the Association satisfied all ongoing monitoring requirements, on the coversheet of all subrecipient contracts in place during the year, a box indicating that the third party was not a subrecipient was incorrectly checked. This error by default incorrectly communicated to their subrecipients that they were contractors. Cause Washington Association of Sheriffs & Police Chiefs’ internal controls related to the review of subrecipient contracts were not functioning properly causing the pervasive error to be overlooked. Effect or potential effect Subrecipients were not clearly communicated their roles. Questioned costs N/A Repeat audit finding No Recommendation We recommend that Washington Association of Sheriffs & Police Chiefs ensure there is a proper understanding of the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes Views of responsible officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report

Significant deficiency in internal controls over subrecipient monitoring. • Program Title: Substance Abuse Block Grants • Assistance Listing Number: 93.959 • Federal award identification number: B08TI085843 • Federal Agency: Department of Health and Human Services • Pass-through Entity: Washington State Health Care Authority Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D section 2 CFR 200.332 requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward. Condition/Context Washington Association of Sheriffs & Police Chiefs (the Association) passes substantially all federal funding through to subrecipients. During testing it was identified that, although the Association satisfied all ongoing monitoring requirements, on the coversheet of all subrecipient contracts in place during the year, a box indicating that the third party was not a subrecipient was incorrectly checked. This error by default incorrectly communicated to their subrecipients that they were contractors. Cause Washington Association of Sheriffs & Police Chiefs’ internal controls related to the review of subrecipient contracts were not functioning properly causing the pervasive error to be overlooked. Effect or potential effect Subrecipients were not clearly communicated their roles. Questioned costs N/A Repeat audit finding No Recommendation We recommend that Washington Association of Sheriffs & Police Chiefs ensure there is a proper understanding of the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes Views of responsible officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report