Condition: The Organization did not fully document compliance with certain federal subrecipient monitoring requirements, including completion of pre-award risk assessments prior to initial payments, timely follow-up on monitoring deficiencies, and processing subrecipient payments within the required...
Condition: The Organization did not fully document compliance with certain federal subrecipient monitoring requirements, including completion of pre-award risk assessments prior to initial payments, timely follow-up on monitoring deficiencies, and processing subrecipient payments within the required 30-day timeframe. Response: The Organization concurs with the finding. Corrective Action Plan: The Organization has taken and continues to take corrective actions to strengthen its subrecipient monitoring framework and ensure full compliance with federal requirements under 2 CFR 200. Specifically, the Organization has implemented the following actions: 1. Revised Subaward Agreements The Organization has revised its subaward agreements to ensure compliance with 2 CFR 200.332(a), including all required federal award identification elements, flow-down provisions, performance requirements, and administrative controls. Revised agreements have been executed with subrecipients as required. 2. Formalized Subrecipient Monitoring Policies and Procedures The Organization has adopted a comprehensive Subrecipient Selection, Evaluation, Award, and Post-Award Oversight Policy, which establishes a risk-based lifecycle approach to subrecipient management. The policy addresses pre-award risk assessment, subaward issuance, post-award monitoring, corrective actions, and closeout procedures in accordance with 2 CFR 200.332 and related requirements. 3. Pre-Award Risk Assessments Implemented Prior to Payment Prior to the start of subrecipient enrollments and program operations, the Organization collected narrative and qualitative information regarding subrecipient capacity, experience, and readiness. However, this information had not yet been formally documented using a standardized evaluation and risk rating tool. As part of the corrective action, the Organization has now formalized these practices through a structured pre-award risk assessment template that results in an actionable risk rating (Low, Moderate, or High) and directly informs monitoring intensity and oversight activities. The Organization has implemented standardized pre-award risk assessments for all subrecipients, and risk assessments have been completed for each current subaward using the new template. Suspension and debarment status is verified through SAM.gov prior to subaward execution and documented in the organization records. 4. Enhanced Post-Award Monitoring and Follow-Up Procedures The Organization has strengthened post-award monitoring practices using monitoring plans informed by assigned risk levels. Monitoring activities include scheduled site visits, desk reviews, and documented follow-up on identified deficiencies. During the second half of FY 2024–2025, the Organization further enhanced its follow-up processes by implementing a more structured Corrective Action Plan (CAP) tracking system, including formal email reminders to subrecipients regarding CAP submission deadlines, written acknowledgment upon receipt of CAPs, and documented review and resolution of submitted CAPs. These improvements have resulted in more timely follow-up and clearer documentation of compliance activities. 5. Improved Payment Processing Controls The Organization has implemented internal controls to improve the timeliness of subrecipient payment processing, including clearer review workflows, tracking mechanisms, and staffing adjustments to support compliance with the 30-day payment rule. Responsible Official: Gloria Meridew, Director of Finance Anticipated Completion Date: Corrective actions have been fully implemented as of the date of this letter. The Organization will continue to monitor compliance and maintain documentation to support sustained adherence to federal subrecipient monitoring and payment requirements.