VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized ove...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized oversight procedures to ensure full compliance with all federal pass-through entity responsibilities. Action Steps: 1. Develop and implement a formal "Entity Classification Protocol" based on 2 CFR §200.331 to correctly identify subrecipients versus contractors for all existing and future TANF agreements. 2. Redesign all subaward templates to include the mandatory thirteen (13) elements required by 2 CFR §200.332(a), including FAIN, ALN, period of performance, and audit access clauses. 3. Implement a mandatory Subrecipient Risk Assessment tool to evaluate every subrecipient's fraud risk, financial management capacity, and history of audit findings before funding is disbursed. 4. Establish a monitoring protocol that includes mandatory reviews of financial and performance reports, verification of Single Audits (Subpart F), and scheduled on-site programmatic site visits. 5. Create a formal "Enforcement Policy" to manage subrecipient Non-Compliance, outlining the process for issuing management decisions on audit findings and implementing corrective action plans. 6. Launch an intensive training program for all program and procurement staff on the Uniform Guidance requirements for pass-through entities, focusing on proper identification, monitoring, and federal reporting accountability. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational ServicesVIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized oversight procedures to ensure full compliance with all federal pass-through entity responsibilities. Action Steps: 1. Develop and implement a formal "Entity Classification Protocol" based on 2 CFR §200.331 to correctly identify subrecipients versus contractors for all existing and future TANF agreements. 2. Redesign all subaward templates to include the mandatory thirteen (13) elements required by 2 CFR §200.332(a), including FAIN, ALN, period of performance, and audit access clauses. 3. Implement a mandatory Subrecipient Risk Assessment tool to evaluate every subrecipient's fraud risk, financial management capacity, and history of audit findings before funding is disbursed. 4. Establish a monitoring protocol that includes mandatory reviews of financial and performance reports, verification of Single Audits (Subpart F), and scheduled on-site programmatic site visits. 5. Create a formal "Enforcement Policy" to manage subrecipient Non-Compliance, outlining the process for issuing management decisions on audit findings and implementing corrective action plans. 6. Launch an intensive training program for all program and procurement staff on the Uniform Guidance requirements for pass-through entities, focusing on proper identification, monitoring, and federal reporting accountability. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational Services