2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subr...
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
• 2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1) through (4).
• 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients”. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, “counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 – 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs, and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above was identified during our procedures related to subrecipient monitoring and was pervasive to the program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is appropriately documented.
Management Response and Corrective Action:
1. Person Responsible: Karen Vu, Procurement Contract Manager, Senior
2. Corrective Action Plan:
An activity tracker spreadsheet (check list) was developed and implemented in September 2023 to ensure timely completion of subrecipient monitoring activities. The check list is not a requirement of 2 CFR 200.332, the checklist and risk assessment form were shared with the Auditors during prior year's Single Audit, and the auditors did not raise any concerns related to either during the audit. The subrecipient risk assessment and the monitoring activity tracker is reviewed by supervisors; however, review was not documented. We will accept the auditor’s recommendation and add a signature line to the risk assessment and activity tracker to document review by a supervisor.
3. Anticipated Implementation Date: April 2025