Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those clas...
Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those classifications, CARS did not apply all of the formal subrecipient monitoring requirements of 2 CFR § 200.332 to these entities. Specifically, formal subrecipient risk assessments were not performed or documented, verification of required audits under Subpart F was not incorporated into a formal monitoring process, and certain subrecipient agreements contained incorrect Assistance Listing Numbers (ALNs). CARS believes it is important to distinguish the identified deficiencies from an absence of risk evaluation, oversight or monitoring of the entities. Although CARS did not perform or document formal subrecipient risk assessments in accordance with 2 CFR § 200.332, management considered factors relevant to organizational risk during the initial proposal and partner-selection process. These considerations included CARS’ prior experience with the organizations, their demonstrated performance and funding histories, organizational capabilities, and experience administering federally funded programs, as applicable. The basis for partner selection and related considerations were reflected in the proposal documentation. During the period under audit, CARS reviewed and approved reimbursement requests for allowability and performed ongoing programmatic monitoring of performance and progress. However, because the entities were classified as contractors/vendors, these risk evaluation and monitoring activities were performed within CARS’ existing proposal, vendor, and program oversight processes rather than within a formal subrecipient monitoring framework designed to address all requirements of 2 CFR § 200.332. Based on additional training regarding subaward management under 2 CFR Part 200 and the matters identified during the current audit, management recognizes that formal written policies, documented classification determinations, and additional monitoring controls are necessary to ensure that entities determined to be subrecipients are consistently monitored in accordance with applicable Uniform Guidance requirements. CARS began corrective action and, prior to issuance of the audit report, completed the following: 1. Confirmed the correct Assistance Listing Number for the NTTAC federal award and identified subrecipient agreements requiring correction; 2. Issued modifications to affected subrecipient agreements, as necessary, to communicate the correct ALN for the applicable Year 5 modifications; 3. Reviewed available subrecipient SEFA information related to FY2025 expenditures to evaluate the accuracy of the reported ALN and communicated necessary corrections, as applicable; and 4. Obtained and reviewed available Single Audit information for the affected subrecipients and confirmed that no findings related to federal funding received from CARS were identified in the reports reviewed. Corrective Action CARS will formalize and document its existing procedures as they specifically relate to subrecipients and the applicable requirements of 2 CFR § 200.331 and § 200.332. The policy and related procedures will include documented subrecipient-versus-contractor determinations; subrecipient risk assessments; verification of required subaward information, including the Assistance Listing Number (ALN); review of financial and programmatic performance information; verification of applicable Subpart F audit requirements; review and follow-up of audit findings or other significant developments; and documentation and retention of monitoring activities, conclusions, and corrective actions, as applicable. CARS will also establish a documented pre-execution review and approval control for applicable federally funded agreements to verify the appropriate classification of the relationship and the accuracy and completeness of required federal award information before execution. As part of implementation, CARS will review applicable existing federally funded agreements under the new policy. If an existing relationship is determined to meet the criteria of a subrecipient rather than a contractor, CARS will appropriately classify the agreement, correct applicable federal award information, including the ALN, as necessary, and apply and document the required subrecipient monitoring procedures prospectively. Responsible Party: Ranelle Bensch, Director of Finance & Compliance Target Implementation Date: March 2027