Finding 2022-001 – Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.331(d), pass-through entities are required to monitor the activities of subrecipients as necessary to ensure that subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. Additionally, effective subrecipient monitoring should include review of financial and compliance reporting, follow-up on deficiencies, and ensuring that subrecipients properly meet Federal and other compliance requirements. Condition: During our testing of subrecipient monitoring controls, we noted that the Organization did not adequately monitor a subrecipient that was awarded Federal funds. Specifically, the subrecipient failed to collect and remit required payroll taxes and did not file quarterly IRS Form 941 payroll tax returns. The Organization did not identify these compliance issues in the course of its monitoring procedures. Cause: The Organization has not established sufficient subrecipient monitoring procedures to verify that subrecipients are fulfilling all required financial, tax, and compliance obligations. Monitoring activities typically involved reviewing invoices, time sheets, program reports, but did not include reviewing for compliance with Federal payroll and tax reporting requirements. Furthermore, there was not a clear understanding between the grantor (City of Chicago), the Community Based Organizations and the Chicago Parks Foundation regarding the necessity to specially monitor the process of payroll tax return preparation. Effect: Failure to adequately monitor subrecipients increases the risk of noncompliance with Federal requirements and could result in questioned costs, repayment of Federal funds, penalties, or reputational risk to the Organization as the pass-through entity. The absence of proper oversight also exposes Federal awards to potential misuse or mismanagement by the Community Based Organization, which where the subrecipients. Questioned Costs: At the time of our audit, the amount of questioned costs, if any, has not been determined. Recommendation: We recommend that the Organization strengthen its subrecipient monitoring procedures by: • Implementing monitoring activities that include verification of payroll tax filings (e.g., IRS Form 941) and remittances for subrecipients. • Establishing policies requiring periodic certification or submission of compliance documentation from subrecipients. • Providing training to staff responsible for subrecipient monitoring to ensure all aspects of Federal compliance are addressed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Organization will implement enhanced monitoring procedures, including requiring subrecipients to provide evidence of payroll tax compliance, and will expand its monitoring checklist to ensure IRS filing obligations are met.