Agencies: Corporation for National Community Service and U.S. Department of Health and Human Services Federal Program: All federal awards Criteria: The Uniform Guidance requires PHIMC to submit the Data Collection Form and single audit reporting package to the Federal Audit Clearinghouse within the earlier of nine months following its fiscal year end, or 30 days after receipt of the auditors' report. Condition: PHIMC did not submit its 2025 Data Collection Form and single audit reporting package to the Federal Audit Clearinghouse before the deadline of September 30, 2026. In addition, PHIMC's Consolidated Year End Financial Report (CYEFR) required by the Grant Accountability and Transparency Act was also submitted late. Context: The 2025 single audit reporting package was due to the Federal Audit Clearinghouse no later than September 30, 2026. However, as a result of significant turnover in the business office, there were delays in completing the single audit. The CYEFR was due September 30, 2026. Cause: Significant turnover in the business office led to delays in starting and completing the single audit. Questioned Costs: None identified. Effect: Timely reporting to governmental agencies was not achieved. Grantor agencies may reduce or withdraw funding if compliance requirements are not met. Recommendation: We recommend that PHIMC establish and maintain a formal compliance reporting calendar that identifies the applicable due dates, responsible personnel, required review and approval steps, and submission status for the Data Collection Form, Single Audit reporting package, and CYEFR. Management should monitor the calendar throughout the reporting process and ensure sufficient personnel or third-party resources are available to complete, review, and submit each required filing by the applicable deadline. Views of Responsible Officials: Management concurs and will develop a reporting calendar to be reviewed with responsible management to ensure the organization has the capability to meet future deadlines.
Agencies: U.S. Department of Health and Human Services Pass-through Agency: Illinois Department of Public Health Federal Program: HIV Prevention Activities - Health Department Based Assistance Listing Number: 93.940 Criteria: The applicable version of 2 CFR § 200.332 requires a pass-through entity to communicate required federal award information to each subrecipient, evaluate each subrecipient’s risk of noncompliance to determine appropriate monitoring, monitor the subrecipient’s activities, follow up on identified deficiencies, and verify compliance with applicable single audit requirements. Condition: For two subrecipients selected, PHIMC maintained executed agreements and performed documented programmatic and fiscal monitoring through administrative site visits. However, PHIMC did not maintain formal, written overarching subrecipient monitoring policies and procedures governing required federal award information, subrecipient risk assessments, risk-responsive monitoring, single audit applicability determinations, follow-up of identified matters, and supervisory review. In addition: • The agreements did not contain all required federal award information, and PHIMC did not provide evidence that the omitted information was otherwise communicated; • PHIMC did not perform or document a risk assessment supporting the nature and extent of monitoring; and • PHIMC did not retain documentation supporting its determination that the subrecipients were not subject to Single Audit requirements. Context: PHIMC provided funding to 14 subrecipients during the year. We selected two subrecipients for testing and identified the conditions described above in both selections. The sample was not, and was not intended to be, statistically valid. PHIMC performed substantial programmatic and fiscal monitoring through documented site visits, including review of financial information, payroll, receipts, program performance, data reporting, and progress toward program objectives. However, this monitoring did not compensate for the absence of required federal award information or documented risk assessments. Cause: PHIMC had not established formal, written overarching subrecipient monitoring policies and procedures or a standardized supervisory review process to ensure that required federal award information, documented risk assessments, Single Audit applicability determinations, and related monitoring documentation were completed and retained. Questioned Costs: No questioned costs were identified. Effect: PHIMC cannot demonstrate that each subrecipient received all required federal award information or that the nature and extent of monitoring was based on an assessment of the subrecipient’s risk of noncompliance. As a result, there is an increased risk that: * Subrecipients may not receive all information needed to administer federal awards in accordance with applicable requirements; • Monitoring may not be appropriately tailored to the risks presented by each subrecipient; • Subrecipients required to undergo a Single Audit may not be timely identified; and • Subrecipient noncompliance may not be prevented, detected, or corrected on a timely basis. No unauthorized expenditures or failures to perform programmatic and fiscal monitoring were identified through the procedures performed. Recommendation: We recommend that PHIMC develop, document, and implement comprehensive subrecipient monitoring policies and procedures that require: • Use of a standardized subaward agreement or checklist containing all required federal award information; • A documented risk assessment for each subrecipient; • Monitoring procedures responsive to the assessed risk; • A documented determination of Single Audit applicability and verification of completion when required; • Documentation of follow-up and resolution of identified monitoring matters; and • Documented supervisory review confirming that all required subrecipient monitoring procedures were completed and retained. PHIMC should provide training to responsible personnel and require a documented supervisory review of each subrecipient file at award execution, during monitoring, and at closeout. Views of Responsible Officials: Management concurs and PHIMC will develop, document, and implement required subrecipient monitoring policies and procedures.