As part of our current policies and procedures review and revision
process, we plan to incorporate the subrecipient monitoring and
management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of
the Uniform Guidance to emphasize accountability and compliance
in managing federal funds and subrecipients....
As part of our current policies and procedures review and revision
process, we plan to incorporate the subrecipient monitoring and
management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of
the Uniform Guidance to emphasize accountability and compliance
in managing federal funds and subrecipients.
Specifically and prospectively, effective November 1, 2024, the
Organization’s practices will include:
1. Using a checklist for the determination of subrecipient or
contractor classification as guidance; Perform a comprehensive risk
assessment before entering into any
subrecipient agreement.
2. Provide identification details such as CFDA number,
amount of federal funds obligated, and the award period
for determined subrecipient awards.
3. Require subrecipients to submit programmatic and
financial reports as specified in the subrecipient
agreement.
4. As part of the subrecipient process, ensure subrecipients
that expend $750,000 or more in federal funds during a
fiscal year undergo a single audit in accordance with 2
CFR Part 200, Subpart F. Review their audit reports and
address any findings related to their federal awards, taking
appropriate corrective actions
Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and
July 1, 2023 – June 30, 2024, the Organization will perform a risk
assessment of the existing subrecipient portfolio during this period to
identify high-priority risks. The objective of this risk assessment
review is to identify, evaluate, and prioritize risks that could
adversely impact the organization’s ability to achieve its strategic,
operational, and quality assurance goals, ensuring that all products,
services, and processes align with established standards and fulfill
processes.
The above reflects the current planned practices of the Organization
and the overall financial policies and procedures are in the process of
being updated to align to the subrecipient monitoring and
management provision of 2 CFR §200.331 and 2 CFR §200.332 of
the Uniform Guidance. The Organization has prioritized the
completion and distribution of the updated financial policies and
procedures by December 31, 2024.