Audit 371759

Finding No: 2024.001 Type: Significant Deficiency - Internal Control: Subrecipient Monitoring Condition: We were not able to substantiate evidence of monitoring grants to others. Criteria: Under 2 CFR 200.332, pass-through entities are required to monitor the activities of subrecipients as necessary to ensure that federal funds are used for authorized purposes in compliance with statutes, regulations, and terms and conditions of the award. This includes evaluating risk of noncompliance, conducting reviews (desk or on-site), following up on deficiencies, and ensuring timely corrective action, as well as resolving audit findings specific to the subaward. Internal control over compliance requirement related to subrecipient monitoring was not evidenced. Amount: not applicable Cause: The nonprofit did not implement sufficient monitoring processes over its subrecipients. Effect or Potential Effect: Failure to monitor subrecipients increases the risk of misused federal funds, nonachievement of performance goals, or uncorrected compliance issues. This can potentially result in questioned costs, the need for repayment of grant funds, reputational damage, and jeopardized future grant eligibility. Repeat Audit Finding: No Recommendations: Establish and implement a risk-based subrecipient monitoring plan that includes documented risk assessments, regular desk and/or on-site reviews, timely followup and resolution of deficiencies, and maintenance of supporting documentation for all monitoring activities. Provide training to staff on subrecipient monitoring requirements and ensure formal procedures comply with 2 CFR 200.332.

Finding No: 2024.002 Type: Significant Deficiency - Internal Control: Procurement Condition: We were not able to substantiate evidence of confirming suspension and debarment for vendors. Criteria: Under 2 CFR 200.214, non-federal entities must verify that subrecipients and contractors are not suspended, debarred, or otherwise excluded from participation in federal programs before entering into covered transactions. Checks should be performed using the System for Award Management (SAM). Internal control over compliance requirement related to suspension and debarment was not evidenced. Amount: not applicable Cause: The nonprofit does not have documented procedures to verify the suspension and debarment status of entities prior to awarding contracts or subawards. No evidence was available to confirm that such checks were performed for current awards. Effect or Potential Effect: Absence of adequate suspension and debarment screening increases the risk of federal funds being awarded to ineligible parties, potentially resulting in repayment of those funds, audit findings, and possible exclusion from future grant programs. Repeat Audit Finding: no Recommendations: Implement and document procedures requiring SAM exclusion checks prior to issuing federal subawards or contracts and maintain records of these checks. Provide staff training on regulatory requirements regarding suspension and debarment, and regularly review compliance to ensure ongoing adherence.