Findinq No.:2022-023 Subrecipient Monitoring
Responding Agency: Department of Administration (DOA)
Responsible Personnel: Edward M. Birn, Director (DOA)
As for Fiscal Year 2022, payments to beneficiaries under the GEDA program were made directly
by DOA. GEDA was not in receipt of any funds and by t...
Findinq No.:2022-023 Subrecipient Monitoring
Responding Agency: Department of Administration (DOA)
Responsible Personnel: Edward M. Birn, Director (DOA)
As for Fiscal Year 2022, payments to beneficiaries under the GEDA program were made directly
by DOA. GEDA was not in receipt of any funds and by that plain language cannot be considered
a subrecipient. DOA determined in accordance with 2CFR 200.331 that GEDA was not a
Subrecipient: Auditors may, but have not to date, requested access to GEDA and DOA records
for verification eligibility. CFRS200.331 reads.' "(c) Use of judgment in making a
determination. ln determining whether an agreement between a
pass-through entity and another non-federal entity casts the latter as a subrecipient or a contractor, the substance
of the relations is more important than the form of the agreement. All the characteristics
listed above may not be present in all cases, and the pass-through entiflr must use
judgement in classifying each agreement as a subaward or a procurement contract."