Audit 404493

Finding 2025-002 – Incomplete Subrecipient Agreements and Inaccurate Subrecipient SEFA Reporting Federal Program: Violence Against Women Formula Grants Assistance Listing Number: 16.588 Compliance Requirement: Subrecipient Monitoring Internal Control Deficiency: Material Weakness - Insufficient controls over subaward agreement content and subrecipient reporting oversight Compliance Finding: Subaward agreements missing required elements; subrecipient failed to report pass-through funds on its SEFA Questioned Costs: None Criteria: Under 2 CFR § 200.332, pass-through entities must ensure that all subaward agreements contain specific federal award information, monitoring expectations, and required terms and conditions. Subrecipients must report federal expenditures on their SEFA in accordance with 2 CFR § 200.510(b). Condition: During our testing of subrecipient monitoring and federal reporting, we noted that subrecipient agreements did not include several elements required under 2 CFR § 200.332(b), (c), and (e)–(i). Specifically, the agreements reviewed were missing one or more of the following required components: • Federal award identification information, including unique entity identifier (UEI), Federal Award Identification Number (FAIN), ALN, award date, and other required identifiers. • Required access-to-records language granting the pass-through entity, auditors, and federal agencies the right to access pertinent records. • Subaward-level closeout requirements, including timelines and documentation expectations. In addition, during compliance testing we noted that the subrecipient did not include the pass-through funds received in its own SEFA, resulting in incomplete federal expenditure reporting. Cause: The deficiencies appear to result from the absence of a standardized subaward agreement template and insufficient review procedures to ensure all Uniform Guidance elements are included. The subrecipient’s SEFA omission appears to stem from a lack of communication and monitoring regarding reporting requirements. Effect: Incomplete subaward agreements increase the risk that subrecipients may not understand federal requirements, may apply incorrect cost principles, or may fail to comply with federal terms. Missing SEFA reporting by the subrecipient results in inaccurate federal expenditure reporting and may affect federal oversight, risk assessments, and audit coverage.Recommendation: Management should implement a standardized subaward agreement template that incorporates all elements required under 2 CFR § 200.332. If any of the required elements are missing, adding a short federal award information/Uniform Guidance appendix and an explicit records-access and closeout article would bring the contracts into compliance. Management should also strengthen monitoring procedures to ensure subrecipients understand and comply with SEFA reporting requirements, including verifying that pass-through funds are properly reported. Management’s Response and Corrective Action Plan is found on page 28-29.

Finding 2025-001 – Accuracy of Schedule of Expenditures of Federal Awards (SEFA) Compliance Requirement: Reporting Internal Control Deficiency: Significant Deficiency - Insufficient review over SEFA preparation Compliance Finding: SEFA reported incorrect Assistance Listing Numbers (ALNs) Questioned Costs: None Criteria: Per 2 CFR 200.510(b), auditees must prepare a SEFA that accurately identifies federal programs by the correct ALN. Condition: The SEFA submitted for the audit included incorrect ALNs for certain federal programs which misidentified a Type A program and omitted a major program. Cause: The errors appear to have resulted from inadequate procedures to verify ALNs against federal award documentation during SEFA preparation. Effect: Incorrect ALNs may result in inaccurate identification of federal programs and increase the risk of misidentification in major program determination, potentially affecting audit scope and compliance conclusions. Recommendation: Management should implement procedures to verify that ALNs reported on the SEFA agree to authoritative federal award documentation prior to finalization. Management’s Response and Corrective Action Plan is found on page 28-29.