Audit 399554

Federal Program WIOA Cluster – Assistance Listing Number 17.258, 17.259, 17.278 American Rescue Plan Act (ARPA) – Assistance Listing Number 21.027 Criteria WIOA: The requirements of 2 CFR Part 170 Appendix A states that direct recipients of grants or cooperative agreements are required to report first-tier subawards of $50,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month in which the direct recipient awards such subawards.Part 3 of the compliance supplement requires this reporting at $30,000. ARPA: The grant agreement with the pass-through agency states that monthly reports must be submitted to the agency by the 15th day following the end of each month. Condition WIOA: During the audit, we noted reporting of subaward information to FSRS was not performed. ARPA: During the audit, we noted several monthly reports were sent to the granting agency after the deadline. Cause The entity did not have sufficient controls in place to ensure reporting was completed in the required timeframe. Effect The entity could jeopardize future grant funding due to program noncompliance. Questioned Costs No questioned costs. Recommendation We recommend the entity implement a tracking system to remind staff of the various reports due and respective deadlines. Context/Sampling WIOA: During the audit, auditor requested a sample of required FSRS reporting for three subrecipients and was unable to obtain the required reporting. ARPA: During the audit, we evaluated a haphazardly selected sample of 4 monthly reports. Three of these reports were found to have been sent to the granting agency after the deadline.

Federal Program WIOA Cluster – Assistance Listing Number 17.258, 17.259, 17.278 Criteria The requirements per Part 4 of the compliance supplement states that a minimum of 75 percent of the Youth Activity funds allocated to states and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth. Condition During the audit, we noted the 75 percent minimum requirement was not met. Cause The entity did not have sufficient controls in place to ensure that expenditure requirement was met or to submit a waiver to bring the requirement down. Effect The entity could jeopardize future grant funding due to program noncompliance. Questioned Costs No questioned costs. Recommendation We recommend the entity implement a tracking system to remind staff of the various expenditure requirements. Context/Sampling During the audit, we obtained support for expenditures incurred for youth out-of-school that were at 66%. The partnership previously submitted a waiver WIOA Section 129(a)(4)(A) for Program Year 2022-2023 to bring the out-of-school expenditure requirement from 75% to 50%, but did not do so for the fiscal year under audit.

Criteria Under 2 CFR 200.332(b), pass-through entities must provide specific information to subrecipients at the time of subaward, including at minimum the Assistance Listing number and title, Federal Award Identification, Subaward Period of Performance, Total amount of Federal funds, name of Federal agency, indirect cost rate, and all applicable Federal statutes, regulations, and the terms and conditions of the Federal award, among other elements. Condition The auditee, acting as a pass-through entity, did not inform subrecipients of the required information at the time of subaward. Cause The entity did not have sufficient controls in place to ensure that all required information under Uniform Guidance were communicated to subrecipients at the time of the award. Effect Subrecipients may be unaware of key Federal requirements, which can increase the risk of noncompliance with allowable costs, reporting, and audit requirements. Questioned Costs No questioned costs. Recommendation We recommend the entity implement a process to perform subrecipient vs. contractor determinations for organizations it engages with using federal funding, and ensure the appropriate language required by Uniform Guidance is included in the agreement. Context/Sampling During the audit, we examined agreements with two other entities that the auditee contracted with to perform program activities.