Summary of Findings Auditors noted there was missing documentary evidence of the following subrecipient monitoring requirements: obtain budgets for reasonable expenses from subrecipients, monitoring of quarterly subrecipient reports, subrecipient contract agreements, site visits, and receiving updat...
Summary of Findings Auditors noted there was missing documentary evidence of the following subrecipient monitoring requirements: obtain budgets for reasonable expenses from subrecipients, monitoring of quarterly subrecipient reports, subrecipient contract agreements, site visits, and receiving updated audit reports from subrecipients and issuing management decisions over federal award findings for pass through entities. We consider this condition to be a material weakness to the Subrecipient Monitoring compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. There were no questioned costs. Statement of Concurrence or Nonconcurrence MNADV concurs with the finding and recommendation labeled 2023-006. The organization served as a passthrough entity for federal grant funds. MNADV believed that it was in compliance with monitoring responsibilities as outlined in the grant agreement from the Maryland Governor’s Office on Crime Prevention, Youth and Victim Services (GOCPYVS) which stated: 3.7. MNADV Monitoring and Reporting of Subrecipients Sub-recipients will be required to submit quarterly programmatic reports to MNADV regarding grant activities, goals, objectives, and performance measures. MNADV will monitor the subrecipient receiving funds, including those that serve underserved populations. This may include reviewing progress reports, reasonable performance measures, financial reports, standard FVPSA required statistics, desk site visits, audits, regular communications, or other monitoring activities as required by federal or state regulation. Information regarding sub-recipients’ activities will be included in MNADV’s quarterly program reports to GOCPYVS. MNADV did employ the following monitoring activities outlined above: • Collected and reviewed progress reports • Collected and reviewed reasonable performance measures • Collected and reviewed financial reports • Collected and reviewed standard FVPSA required statistics • Maintained regular communications with subgrantees Because the grant award language uses the term ‘may include’, we did not interpret this language as requiring us to conduct audits or site visits. Information regarding sub-recipients’ activities based on information gathered during monitoring was included in MNADV’s quarterly program reports to GOCPYVS. However, the organization does concede that it did not meet all the monitoring requirements outlined in 2 CFR 200. Corrective Action A. Immediate Corrective Actions Taken No immediate action could be taken as all subgrants subject to this audit were closed at time of audit. B. Long-Term Corrective Action Plan MNADV will develop and implement a comprehensive written Subrecipient Monitoring Policy that complies with 2 CFR 200.331–200.333 and clearly distinguishes between grant agreement language and federal compliance requirements. Responsible Parties: Executive Director and Subgrantee Program Monitor Completion Target: Within 60 days of the date of this memo.