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The Department will continue to follow the current Policy and Procedure related to the Single Audit reviews and has allocated an individual to review the Single Audits. This includes issuing a management decision letter if required, in accordance with the timeline established in federal guidance.
The Department will continue to follow the current Policy and Procedure related to the Single Audit reviews and has allocated an individual to review the Single Audits. This includes issuing a management decision letter if required, in accordance with the timeline established in federal guidance.
The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitori...
The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitoring requirements were completed. The agency is in the process of strengthening its policies as they are related to subrecipient monitoring. The agency is in the process of reviewing and strengthening its internal policy related to subrecipient monitoring. The agency is working with the State Controller’s Office to include subrecipient monitoring training which will take place in early 2026. The agency is implementing standardized processes to include subrecipient checklist that will be included in all agreements that will identify if the agreement is a subrecipient or contract. The agency is working to ensure all agreement templates have correct subrecipient language Per 2 CFR §200.332 prior to submission for signatures.
2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication ...
2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication kept within subaward files. For future subawards, the Department of Agriculture will create a checklist based on 2 CFR 200.332 (b)(1) to use in review of new agreements (one checklist per funding source), including section citations for the required elements.
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subr...
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subrecipient activities as required under FFATA regulations. However, the lack of a clearly defined responsibility for this task resulted in non-compliance. Management recognizes this gap and is committed to implementing corrective measures to ensure full compliance moving forward.
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although ...
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although procedures exist for verifying SAM.gov registration (suspension/debarment status) and obtaining audited financial statements from subgrantees, these procedures were not documented or codified in the Caminos Nacional Policy Manual. Pre-award risk assessments have been conducted informally without a formal determination of risk, and protocols surrounding risk assessment were inadequately documented, resulting in inconsistent implementation.
Finding No. 2025-001 – Subrecipient Monitoring – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: UWNYC will implement a formal annual subrecipient audit verification procedure to ensure compliance with 2 CFR 200.332(g). Staff will annually determine and document whet...
Finding No. 2025-001 – Subrecipient Monitoring – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: UWNYC will implement a formal annual subrecipient audit verification procedure to ensure compliance with 2 CFR 200.332(g). Staff will annually determine and document whether each subrecipient is subject to Single Audit requirements under 2 CFR Part 200, Subpart F. For subrecipients subject to these requirements, staff will obtain and review the final Single Audit report, document the review, and consider any identified audit findings as part of the subrecipient risk assessment to inform the level and nature of ongoing monitoring. These procedures will be documented and incorporated into UWNYC’s subrecipient monitoring internal controls. Anticipated Completion Date: Initial review by September 30, 2026 Person(s) Responsible for Corrective Action: Eichakeem McClary, Chief Legal Officer (212.251.4093) Tanisha McKnight, Chief Operations Officer (212.251.4010)
Finding 2025-001 Condition The auditors reviewed MATC’s subaward agreement with Literacy Services of Wisconsin, noting that some of the required information under 2 CFR 200.332 Section (b) was not included in the contract. Additionally, the auditor noted that MATC did not document the required risk ...
Finding 2025-001 Condition The auditors reviewed MATC’s subaward agreement with Literacy Services of Wisconsin, noting that some of the required information under 2 CFR 200.332 Section (b) was not included in the contract. Additionally, the auditor noted that MATC did not document the required risk assessment process for subrecipients for the year ended June 30, 2025. Corrective Action Plan Corrective Action Planned: MATC has taken immediate steps to address the subaward agreement deficiencies identified under 2 CFR 200.332(b) and to strengthen oversight and monitoring of federal subrecipients. The Dean of Community Education and her team have reviewed and updated the required information that must be included in all federally funded subgrant agreements, including the missing 2 CFR 200.332(a) requirements such as the UEI number, Federal Award Identification Number (FAIN), award dates, and applicable indirect cost rates. MATC’s Office of General Counsel has reviewed and approved an updated subaward agreement template to ensure compliance with the Uniform Administrative Requirements. Process improvements include adoption of a universal subgrant template, clarification of staff responsibilities by shifting the responsibilities to the Grants and Finance Department as related to monitoring subawards, and formal documentation of MATC’s subrecipient risk assessment and monitoring processes. Name(s) of Contact Person(s) Responsible for Corrective Action: ● Dr. Josephine Gomez Dean, Community Education & Strategic Engagement (414) 297-6068 gomezj76@matc.edu ● Stephanie Townsend Manager, Sponsored Project (414) 297-6333 townsens@matc.edu ● Sharon Oleinik (414) 297-7815, Sr. Financial Grants Administrator oleinis1@matc.edu Anticipated Completion Date: Corrective Actions have been completed at the time of this document completion.
Views of Responsible Officials: The Organization's procedure manual will be updated to include procedures that align with 2 CFR 200.332. These procedures will include the documentation of risk assessment for each subrecipient, and establish monitoring activities that are responsive to the level of r...
Views of Responsible Officials: The Organization's procedure manual will be updated to include procedures that align with 2 CFR 200.332. These procedures will include the documentation of risk assessment for each subrecipient, and establish monitoring activities that are responsive to the level of risk.
Corrective Action: Beginning in FY 2026, the Partnerships and Programs Department will formalize and implement procedures within its subrecipient monitoring processes to ensure that all subrecipients subject to the Single Audit requirement are identified and verified as compliant. These procedures w...
Corrective Action: Beginning in FY 2026, the Partnerships and Programs Department will formalize and implement procedures within its subrecipient monitoring processes to ensure that all subrecipients subject to the Single Audit requirement are identified and verified as compliant. These procedures will include annual review of subrecipient expenditures, confirmation of audit submissions when applicable, and documentation of all monitoring activities to ensure ongoing adherence to Uniform Guidance requirements. Proposed completion date: Management will implement the above procedures immediately.
February 6, 2026 Houldsworth, Russo & Co. P.C. 6001 S. Decatur Blvd. Suite P Las Vegas, Nevada 89118 This letter is in response to the audit of the financial statements of United Way of Southern Nevada, Inc. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2025-001 Internal Control...
February 6, 2026 Houldsworth, Russo & Co. P.C. 6001 S. Decatur Blvd. Suite P Las Vegas, Nevada 89118 This letter is in response to the audit of the financial statements of United Way of Southern Nevada, Inc. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2025-001 Internal Controls Systems and Compliance Over Subrecipient Monitoring – U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed Through the State of Nevada Department of Education Criteria: In accordance with 2 CFR 200.332(a)(1), the auditee must maintain a system of internal control to ensure information related to federal awards is clearly identified to the subrecipient at the time of the subaward and if any data elements change, include the changes in a subsequent subaward modification. Condition: The Organization receives funding for the Nevada Ready! program through the State of Nevada Department of Education. The amount of funding provided by Federal and state sources changes annually as does the Federal program from which the funds are derived. The Organization did not receive clear documentation from their grantor on the source of grant funding and did not clarify with the grantor on these requirements. The Organization then did not identify the correct Federal agency and assistance listing number for the grant awards provided to subrecipients. Context: Sixteen preschool centers received notification of subawards with an incorrect Federal agency and assistance listing number for the Federal funds received. Cause: The design and implementation of internal controls over subrecipient monitoring was not operating effectively. Effect: Not communicating the correct Federal agency and assistance listing number in a subaward to subrecipients could result in the subrecipients not complying with Federal regulations. Recommendation: We recommend management design and implement a system of internal controls whereby every subaward that includes Federal funding be clearly identified to the subrecipient as a Federal subaward and include all data elements required to be provided to the subrecipient at the time of the subaward. For any information where the Organization’s grantor has provided unclear or incomplete information, appropriate follow-up with the grantor should be performed. Additionally, if any of the data elements change, those changes should be included in a subsequent subaward modification. Views of Responsible Officials and Planned Corrective Action: We appreciate the identification of this compliance issue and are committed to addressing the finding with a robust corrective action plan. The following steps outline the measures we will take to ensure compliance with federal requirements for subrecipients. 1. Each subaward will be clearly identified as a federal subaward and include all required data elements at the time of issuance. Any subsequent changes will be communicated through a formal subaward modification process. 2. Each required data element will be reviewed and compared to the source data by the preparer and the final signer. If elements are unclear or incomplete, follow-up with the grantor will be performed before the execution of the agreement. If clarity cannot be obtained, the agreements will be executed, noting the area of unclear or incomplete data and that the information will be obtained and updated promptly through a formal subaward modification agreement. 3. In the event subsequent changes occur, these changes will be communicated through a formal subaward notification modification agreement. Responsible Official: Samuel Rudd, President & CEO
The University concurs that annual subrecipient monitoring is required under Uniform Guidance and the OMB Compliance Supplement. Subrecipient monitoring activities are operationally performed within Research and Sponsored Programs (RSP). The lack of documented monitoring during the period under audi...
The University concurs that annual subrecipient monitoring is required under Uniform Guidance and the OMB Compliance Supplement. Subrecipient monitoring activities are operationally performed within Research and Sponsored Programs (RSP). The lack of documented monitoring during the period under audit is attributable to changes in staffing and workflows within RSP, which resulted in a lapse in the consistent execution and documentation of established monitoring procedures. Upon identification of this issue, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP and initiated corrective actions to ensure the subrecipient monitoring requirement will be consistently met going forward. The OoC is working with RSP to reestablish and formalize monitoring procedures and to ensure appropriate staffing resources and review processes are in place. As part of the corrective action plan, the University will complete monitoring in FY2026 for subrecipients with audited financial statements for Fiscal Year 2025 and Calendar Year 2025, where practicable. In addition, as a retrospective measure, the University will review available subrecipient audit reports for Fiscal Year 2024 to confirm whether monitoring requirements were met and to document the results of that review. Further, the OoC and RSP will collaboratively define and document roles and responsibilities for obtaining, reviewing, and retaining subrecipient audit reports on an annual basis. These actions are focused on strengthening annual audit verification procedures for subrecipients, ensure ongoing compliance with Uniform Guidance requirements, and prevent recurrence of the condition.
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of...
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of specific compliance requirements under the Uniform Guidance (2CFR Part 200). We will make sure that all future subrecipients of pass-through federal grants are notified in writing of the responsibility to adhere to federal administrative, cost, and audit requirements.
FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Offi...
FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026
Finding 2025.003 - Subrecipient Monitoring - Material Weakness Recommendation We recommend that management review the Uniform Guidance requirements for subrecipient monitoring and update its policies and procedures as appropriate. We recommend that CLC develop and implement a standardized checklist ...
Finding 2025.003 - Subrecipient Monitoring - Material Weakness Recommendation We recommend that management review the Uniform Guidance requirements for subrecipient monitoring and update its policies and procedures as appropriate. We recommend that CLC develop and implement a standardized checklist outlining all required subrecipient monitoring compliance requirements. The checklist should clearly identify the individual responsible for monitoring and the individual responsible for review, and supporting documentation should be retained to evidence that monitoring requirements have been performed. Planned Corrective Action: Management concurs with the finding and will enhance its subrecipient monitoring process. Corrective actions include: • Update the Financial Policies and Procedures Manual and subaward agreement templates to conform to current Uniform Guidance requirements, including all required subaward data elements (such as Assistance Listing Number, UEI, award identification, and applicable compliance requirements). • Develop and implement a standardized subrecipient monitoring checklist that includes (a) pre-award risk assessment, (b) ongoing monitoring of invoices and programmatic reports, (c) verification of allowable costs, (d) confirmation and review of subrecipient audit requirements and Uniform Guidance reports, as applicable, and (e) documented management review. • Ensure required FFATA subaward reporting is completed timely when applicable, and maintain documentation supporting all monitoring activities. Name of Contact Person: Neil Shah, Interim CFO, neilshah@clcstamford.org Anticipated Completion Date: May 31, 2026 If there are any questions regarding this plan, please contact Neil Shah at neilshah@clcstamford.org.
Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed ...
Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) appear in the agreement. • This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. • This review will also exclude any agreements related to projects classified under Expenditure Category (EC) 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the U.S. Department of Treasury, this EC does not give rise to a subrecipient relationship, therefore UEI information is not required. • For any subgrant agreements with an incorrect or missing UEI or FAIN, the Recovery Office will submit a single memorandum that presents correct UEIs and FAIN to the Board of Estimates (BOE) to ensure that the official record has correct UEI and FAIN information. We believe there is a direct conflict between Treasury guidance and 2 CFR 200 regarding the requirement for active SAM.gov registration. Treasury does not require subrecipients to maintain an active SAM.gov registration and instead permits the use of alternative screening questions in lieu of an active registration. Treasury does not collect individualized subrecipient data for subawards at or below $50,000. Each of these three awards are at or below that threshold, therefore the SAM.gov information, including the subrecipient UEI, registration, or the alternative screening questions, were not collected. The total amount of funding for the three identified subrecipients combined is $100,000. The Recovery Office will require that all subrecipients fully register in SAM.gov. The Recovery Office will require that agencies provide a 30-day window to allow all subrecipients to fully register or funds will be withheld until the subrecipient can fully register to demonstrate the organization is not suspended or debarred. In those cases where the Recovery Office is unable to withhold disbursements for noncompliant subrecipients, the Recovery Office will issue a Corrective Action Plan or issue a finding in the subrecipient's closeout letter. For any grants that expired, if payments occurred outside the period of performance, and did not have written justification for and approval of an extension to the allowable closeout period, the Recovery Office will require that the agency to take the agreement back to the Board of Estimates for a retroactive extension. In certain cases, such as when extended monitoring or implementation of corrective action items go beyond the period of performance, a payment may be made outside of the allowable closeout period. According to 2 CFR 200.344c, "The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward (or an earlier date as agreed upon by the pass-through entity and subrecipient). When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient." In these cases, the Recovery Office will assure there is written justification for the extension on liquidating all financial obligations. Contact Person: Elizabeth Tatum, Director Completion Date: June 30, 2026
Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025...
Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026
Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an inte...
Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts unit. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026
Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed...
Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Subrecipient vs. Contractor determination checklist that are required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Created fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: June 30, 2026
Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...
Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026
Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and ...
Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026
Management is working to obtain the overdue reports.
Management is working to obtain the overdue reports.
Corrective Action Plan: The Finance Department Grants Reporting team will update the City’s grants manual to include additional information on subrecipient monitoring including what documentation is necessary consistent with the requirements in 2 CFR Part 200, Subpart F. The Grants Reporting team wi...
Corrective Action Plan: The Finance Department Grants Reporting team will update the City’s grants manual to include additional information on subrecipient monitoring including what documentation is necessary consistent with the requirements in 2 CFR Part 200, Subpart F. The Grants Reporting team will train department grant managers on the subrecipient monitoring process and its importance and review progress with subrecipient monitoring quarterly with the applicable departments. Persons(s) Responsible for Implementation: William Rand, Financial Manager, Health Department, (816) 513-6353, Email: william.rand@kcmo.org, Cristen Huntz, Financial Analyst, Finance Department, (816) 513-1148, Email: cristen.huntz@kcmo.org, and Robin Flaherty, Financial Manager, Finance Department, (816) 513-1202, Email: robin.flaherty@kcmo.org. Implementation Date: The anticipated implementation date is April 30, 2026.
Name of Contact Person: Tonya Vannasdall, Director. Recommendation: It is recommended that the client implement and document formal procedures to ensure all required subrecipient monitoring activities are performed in accordance with Uniform Guidance, including obtaining and reviewing subrecipient a...
Name of Contact Person: Tonya Vannasdall, Director. Recommendation: It is recommended that the client implement and document formal procedures to ensure all required subrecipient monitoring activities are performed in accordance with Uniform Guidance, including obtaining and reviewing subrecipient audit reports and following up on any identified deficiencies. Corrective Action: The Executive Director will implement the recommendation. Proposed Completion Date: Immediately.
Management agrees with the auditor’s finding 2025-01 Subrecipient Monitoring – Audit Verification. The following action will be taken to ensure that the Subrecipient complies with the single audit requirement: • The Finance Director, Kristie Howell, will correspond with the Subrecipient, Grassy Pond...
Management agrees with the auditor’s finding 2025-01 Subrecipient Monitoring – Audit Verification. The following action will be taken to ensure that the Subrecipient complies with the single audit requirement: • The Finance Director, Kristie Howell, will correspond with the Subrecipient, Grassy Pond Water Company, to clearly state the single audit requirement and due dates. • Cherokee County will request written correspondence from the subrecipient, outlining their course of action and timeline to complete the single audit. • Cherokee County will follow-up with Grassy Pond Water Company on a bi-weekly basis until the 2024 single audit has been submitted, and monthly to ensure that the 2025 audit is being completed as well. • All correspondence will be documented.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subawar...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subaward Agreements that includes all elements required under 2 CFR 200.332(b). This template will be used for any future Subaward Agreements into which CIF enters. 2. CIF created an Amendment template for each active Federal award Subaward/Subrecipient Agreement that includes all elements required under 2 CFR 200.332(b), a requirement to submit period financial reports to CIF, and a section on compliance with audit requirements according to 2 CFR 200.332(g) / 2 CFR 200.501. 3. For each Subrecipient of CIF’s grant NR233A750004G045 under ALN #10.937, formerly known as the Partnerships for Climate Smart Commodities grant but now known as the Advancing Markets for Producers (AMP) program, CIF will use that template to execute an Amendment to the Subaward/Subrecipient Agreement following the execution of the Amendment to the Grant Agreement between CIF and the United States Department of Agriculture (USDA). 4. CIF implemented a schedule for reviewing current subrecipients’ FY 25 Audit Reports after they are published in the Federal Audit Clearinghouse in mid-2026, document the impact of any audit findings on the federally funded program, and implement a corrective action plan. 5. CIF made revisions in the FY 26 update to the CIF Subaward Management & Subrecipient Monitoring Policy and Procedures which will apply to any new subawards. The pre-award risk assessment procedures now include dating and ensure that results are documented prior to subaward execution. The monitoring procedures are now explicitly linked to risk assessment results, with greater oversight required for subrecipients without experience managing Federal funds.
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