2024-002 - Subrecipient Monitoring - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Condition/Context: The Organization do...
2024-002 - Subrecipient Monitoring - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Condition/Context: The Organization does not have a formal risk assessment or oversight program in place to monitor its subrecipients as required under the Uniform Guidance, including ensuring that financial information reconciles between the underlying expenditure reports and the subrecipient/Organization audit reports.
Corrective Action Plan:
CCAP will be implementing the following corrective actions:
1. Formalization of Subaward Documentation:
o We will revise our subaward agreement templates to ensure that all required elements (as outlined in 2 CFR §200.331(a)) are explicitly included.
o All subawards will clearly identify the agreement as a “subaward” and specify required data elements such as the Federal Award Identification Number (FAIN), CFDA/Assistance Listing number, period of performance, and applicable federal terms and conditions.
2. Subrecipient Risk Assessment Framework:
o A standardized risk assessment tool is being developed and will be implemented for all subrecipients prior to executing a subaward.
o This tool will evaluate prior audit history, organizational capacity, experience with federal funds, and other risk indicators as required by §200.331(b).
3. Monitoring and Oversight Procedures:
o We are enhancing our subrecipient monitoring policy to include a tiered approach based on the results of the risk assessment.
o Monitoring activities will include regular desk reviews, periodic programmatic and financial reporting, and site visits for high-risk subrecipients as per §200.331(d)-(e).
4. Audit Verification:
o Our grants team will verify annually that each subrecipient subject to audit under Subpart F has completed the required Single Audit.
o We will obtain and review audit reports and maintain documentation of our review in accordance with §200.331(f).
5. Results Review and Adjustments:
o Any issues identified through audits, site visits, or other monitoring will be evaluated to determine if they necessitate changes in our records, subaward terms, or overall monitoring strategy (§200.331(g)).
6. Enforcement Procedures:
o We are formalizing a process for escalating issues of noncompliance, including written warnings, corrective action plans, suspension of funds, or termination of subawards, as appropriate and consistent with §200.338.