Finding 2025-002 — Subrecipient Monitoring and Required Documentation Corrective Action Plan During fiscal year 2025, the Organization did not consistently obtain or retain: (i) written pre-award risk assessments for subrecipients; (ii) Single Audit reports for subrecipients expending $750,000 or mo...
Finding 2025-002 — Subrecipient Monitoring and Required Documentation Corrective Action Plan During fiscal year 2025, the Organization did not consistently obtain or retain: (i) written pre-award risk assessments for subrecipients; (ii) Single Audit reports for subrecipients expending $750,000 or more in federal awards; or (iii) Unique Entity Identifier (UEI) confirmations via SAM.gov, as required under 2 CFR §§200.331–200.333. The affected pass-through activity totaled approximately $542,500 across three major federal programs (CFDA 93.310, 93.137, and 93.185). Management will implement the following corrective actions: • Establish a centralized subrecipient monitoring file for each subaward relationship, organized by program and award year, and confirm each subrecipient’s active UEI registration in SAM.gov at the time of award and annually thereafter. • Conduct and document a formal pre-award risk assessment using the Subrecipient Risk Assessment Questionnaire, covering prior federal experience, financial stability, internal controls, audit history, and SAM.gov registration. Perform and document a written subrecipient-vs.-contractor determination consistent with 2 CFR §200.331 before entering into or renewing any agreement. • Ensure all subaward agreements include the required award information, compliance responsibilities, reporting requirements, record retention provisions, and audit access provisions under 2 CFR §200.332. • Use the Subrecipient Desk Review Checklist to document quarterly monitoring, including review of progress reports, invoices, deliverables, indirect cost calculations, and personnel timesheets. Require supporting documentation before approving payments. • Maintain an annual Single Audit tracking log to verify federal expenditure thresholds and document collection, review, and resolution of any subrecipient audit findings. • Train program managers and accounting personnel on Uniform Guidance subrecipient monitoring requirements and present updated procedures to the Board/Finance Committee for formal adoption. Responsible Party Executive Director; Accounting Manager; Program Managers; Treasurer/Finance Committee. Completion Date Management has already begun implementation. Full implementation of the monitoring checklist and centralized files expected by September 30, 2026. Review of open FY2025/FY2026 subrecipient files and documentation requests by September 30,2026.