Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
2023-001: Workforce Investment Opportunity Cluster – Assistance Listing #17.258 / 17.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City’s monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.331(a) of the OMB Compliance Supplement, the City should make subrecipients aware of award information. According to the City’s Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring, as well as an increased risk of subrecipient misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two subawards. Recommendation: We recommend performing subrecipient monitoring in accordance with the City’s guidelines and following the procedures laid out in the Program Participant Monitoring Plan. View of Responsible Officials and Planned Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in an inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable Co-coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in the Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monitoring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024.
2023-001: Workforce Investment Opportunity Cluster – Assistance Listing #17.258 / 17.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City’s monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.331(a) of the OMB Compliance Supplement, the City should make subrecipients aware of award information. According to the City’s Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring, as well as an increased risk of subrecipient misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two subawards. Recommendation: We recommend performing subrecipient monitoring in accordance with the City’s guidelines and following the procedures laid out in the Program Participant Monitoring Plan. View of Responsible Officials and Planned Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in an inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable Co-coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in the Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monitoring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024.
2023-001: Workforce Investment Opportunity Cluster – Assistance Listing #17.258 / 17.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City’s monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.331(a) of the OMB Compliance Supplement, the City should make subrecipients aware of award information. According to the City’s Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring, as well as an increased risk of subrecipient misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two subawards. Recommendation: We recommend performing subrecipient monitoring in accordance with the City’s guidelines and following the procedures laid out in the Program Participant Monitoring Plan. View of Responsible Officials and Planned Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in an inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable Co-coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in the Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monitoring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024.
FINDING 2023-213 The Department erroneously determined that two recipients of Temporary Assistance for Needy Families (TANF) funding were contractors instead of subrecipients resulting in noncompliance with the subrecipient monitoring requirements. Type of Finding: Material Weakness, Material Noncompliance Assistance Listing Title: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Number: 2201IDTANF; 2301IDTANF Program Year: October 1, 2021 – September 30, 2022; October 1, 2022 – September 30, 2023 Federal Agency: Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include items such as approvals, authorizations, verifications, reconciliations, and segregation of duties. The Uniform Guidance included in 2 CFR 200.331 describes the Department’s, a pass-through entity, responsibility for completing subrecipient and contractor determinations. The Uniform Guidance included in 2 CFR 200.332 (a) states that pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward. Also, if any of these data elements change, include the changes in subsequent subaward modification. (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal award date (see the definition of federal award date in 2 CFR 200.1 of this part) of award to the recipient by the federal agency; (v) Subaward period of performance start and end date; (vi) Subaward budget period start and end date; (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient; (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings number and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the federal award, including if the de minimis rate is charged per 2 CFR 200.414. If any of the required information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. The Uniform Guidance included 2 CFR 200.332(b) states that pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of federal awarding agency monitoring (for example, if the subrecipient also receives federal awards directly from a federal awarding agency). Condition: The Department erroneously determined that two recipients of TANF funding were contractors instead of subrecipients. A contractor provides services or goods while a subrecipient has additional responsibilities related to the grant administration. Because of that, there are additional requirements when passing through funds to a subrecipient, rather than making a payment to a vendor. We tested one of the two subrecipients for compliance purposes. The award was not identified to the subrecipient as a subaward and did not include all the necessary information at the time of the subaward. In addition, the subrecipient's risk of noncompliance was not evaluated. Cause: During our analysis of the subrecipient monitoring compliance requirement, we learned that the Department’s program staff determined that some of the recipients of TANF funding were contractors. However, the Department’s financial staff reported the expenditures as payments to subrecipients on the SEFA. After investigation, we found that the expenditures were made to subrecipients, not contractors. Effect: The Department is exposed to increased risk of noncompliance related to subrecipients and improper payments in the TANF program. The Department provided a total amount of $1.4 million to subrecipients during fiscal year 2023. Recommendation: We recommend that the Department implement proper training of personnel involved in subrecipient and contractor determinations. In addition, we recommend that the Department design and implement effective internal control procedures to ensure all required information is provided to subrecipients at the time of subawards and that the Department complete the required evaluations of each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Management’s View: The Department agrees with the finding. Corrective Action: The Department has revised our training of personnel involved in subrecipient and contractor determinations. These contract managers and monitors completed grant training on March 12th-13th, 2024 which included sections about subrecipient and contractor determinations, risk assessment and documentation. All newly hired employees will be trained beginning April 2024 with an on-line module. For the impacted vendor, an updated Risk Assessment was completed and submitted to LSO. Additionally, the Department has started the work to effectively change the designation of the vendor and ensure all required information is provided to this subrecipient. This process will be completed by April 30th, 2024. The Department will develop internal control procedures to ensure all required information is provided to the subrecipients at the time of the subawards. These updated internal control procedures will be completed by June 30th, 2024. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that pass-through entities clearly identify to each subrecipient significant Federal subaward information, including identifying award numbers, subaward period dates and budget dates, Federal Assistance Listings number and Title, and appropriate terms and conditions concerning closeout of the subaward. Typically this requirement is satisfied by utilizing a subrecipient contract, reflecting all necessary information, and requiring execution showing acknowledgement of the terms by both parties. 2 CFR section 200.332(b) requires that pass-through entities evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. The evaluation of this risk should include the subrecipient’s prior experience with the same or similar subawards, the results of previous subrecipient audits, whether the subrecipient has new personnel or substantially changed systems, and the extent and results of federal awarding agency monitoring if the subrecipient also receives federal awards directly. 2 CFR section 200.331(f) requires that pass-through entities verify that subrecipients expected to be audited are taking timely and appropriate action on deficiencies detected through audits. Condition: Internal controls should be in place to ensure the City is in compliance with all requirements of the federal award program. For the fiscal year ended June 30, 2023, the following conditions existed: • A risk assessment, required by 2 CFR section 200.332(b), was not performed on the City’s subrecipient of grant funds. • The City did not verify whether the subrecipient of the grant funds was required to be audited, as required by 2 CFR section 200.331(f). • The agreement between the City and its subrecipient did not include a description of the program’s compliance requirements, as required by 2 CFR section 200.331(a), including the specific requirements for the subrecipient’s periodic reporting to the City. Context/Cause: The City did not have adequate internal controls to ensure compliance with subrecipient monitoring requirements. Testing was performed over each requirement for the City, who had a single subrecipient for the fiscal year ended June 30, 2023. Effect: Noncompliance at the subrecipient level may occur due to the subrecipient not being aware of all of the grant’s requirements. Without a risk assessment being performed on the City’s subrecipient for its grant funds, the City will not be aware of problems with staffing or information systems of the subrecipient. Additionally, the City will be unable to effectively monitor the subrecipient if the City is unaware of whether the subrecipient is required to be audited. Recommendation: We recommend the City enhances internal controls to ensure compliance with subrecipient monitoring requirements. Auditee’s Response: We concur with the finding. We will take the necessary steps to ensure that subrecipient agreements include a communication of the federal requirements and that the City performs a risk assessment on subrecipients of federal funding.
Criteria: 2 CFR section 200.331(f) requires that pass-through entities verify that subrecipients expected to be audited are taking timely and appropriate action on deficiencies detected through audits. Condition: Internal controls should be in place to ensure the City is in compliance with all requirements of the federal award program. For the fiscal year ended June 30, 2023, the City did not verify whether the subrecipients of grant funds were required to be audited, as required by 2 CFR section 200.33 (f). Context/Cause: The City did not have adequate internal controls to ensure compliance with all subrecipient monitoring requirements. Testing was performed to determine whether the City verified if the three (3) subrecipients of grant funds were required to be audited for the fiscal year ended June 30, 2023. Effect: Noncompliance at the subrecipient level may occur due to the subrecipient not being aware of all of the grant’s requirements. The City will be unable to effectively monitor the subrecipient if the City is unaware of whether the subrecipient is required to be audited. Recommendation: We recommend the City enhances internal controls to ensure compliance with subrecipient monitoring requirements. Auditee’s Response: We agree with the finding and will ensure controls are put in place to adequately monitor all subrecipient monitoring requirements.
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Subrecipient Monitoring Material Weakness in Internal Control over Subrecipient Monitoring and Material Noncompliance Research and Development Cluster Criteria: In accordance with 2 CFR 200.331, a pass-through entity must make a case-by-case determination whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Additionally, in accordance with 2 CFR 200.332(b), the pass-through entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. In furtherance of this, the pass-through entity should inquire as to whether or not the subrecipient was subject to a Single Audit. If the subrecipient was subject to a Single Audit, the pass-through entity must request the Single Audit report and review for any findings or questioned costs. In accordance with 2 CFR 200.521, the pass-through entity should issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity as applicable. Condition: The Organization does not document its evaluation of each party that it engages in business with as to whether they are a contractor or a subrecipient. For three (3) of the three (3) such parties selected for testing, the Organization did not maintain documentation regarding whether the entity was a subrecipient or a contractor. Furthermore, as it relates to the monitoring of entities determined to be subrecipients, the Organization has not formally documented its subrecipient monitoring procedures to ensure that subrecipients are in compliance with federal statutes, regulations, and the terms and conditions of the subawards. For three (3) of the three (3) subrecipients selected for testing, the Organization did not inquire as to whether the entity was subject to a Single Audit. Consequently, the Organization did not request the Single Audit report nor did they review them for any findings pertinent to the federal award provided to the subrecipient from the pass-through entity. Cause: The Organization did not have an effective process in place to determine whether entities receiving pass-through funds are subrecipients or contractors. Furthermore, once that determination has been made, the Organization did not have a process in place for evaluating subrecipients and their compliance with the applicable requirements of the Uniform Guidance. Effect or potential effect: Lack of proper consideration of subrecipient or contractor status may result in the Organization improperly classifying a recipient of federal funds, which may impact the recipient’s compliance with the Uniform Guidance. Furthermore, by not performing adequate monitoring over subrecipients, the Organization is not appropriately monitoring whether subrecipients are compliance with grant requirements. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should institute a process whereby all entities that receive federal funds have proper documentation supporting their classification as a subrecipient or a contractor for the entire year. Additionally, the Organization should maintain a standardized checklist for all such entities that support their rationale for the classification. This checklist should be prepared by an employee with knowledge of the grant and approved by a second individual. Furthermore, as it relates to subrecipient monitoring, the Organization should institute an annual process whereby all subrecipients are asked whether they received a Single Audit. If the subrecipient was subject to a Single Audit, the Organization should receive and review the Single Audit report. The reviewer should submit a memorandum of any findings relevant to their federal grant, which should then be submitted to the project manager or other designated person for approval. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2022-004
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct
Reference Number: 2023-012 Prior Year Finding: 2022-013 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster, Employment Service Cluster Assistance Listing Number: 17.258, 17.259, 17.278, 17.207, 17.801 Award Number and Year: AA-38535-22-55-A-25 (7/1/2022 – 6/30/2025), AA-36325-21-55-A-25 (4/1/2021 – 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 – 6/30/2023) ES333991955A25 (7/1/2019 – 9/30/2022), ES353492055A25 (7/1/2020 – 9/30/2023), ES367612155A25 (7/1/2021 – 9/30/2024), ES387362255A25 (7/1/2022 – 9/30/2025) DV-35786-21-55-5-25 (10/1/2020 – 12/31/2022), DV-37859-22-55-5-25 (10/1/2021 – 12/31/2023), 23555DV000008 (10/1/2022 – 12/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Compliance: Per 2 CFR section 200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Per 2 CFR section 200.331 - Subrecipient and contractor determinations states, in part, that a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (Department) omitted required federal award information from subawards it issued from the programs and did not adequately monitor subrecipients. Context: WIOA Cluster: Six out of eighteen subrecipients were selected for testing. The following exceptions were noted: • For 6 of 6 subawards issued, the Federal Award Identification Number (FAIN) and Federal award date of award to the recipient by the Federal agency were not included on the subaward agreement. • For 1 of 6 subrecipients selected for testing, no subaward monitoring was performed during the audit period. • For 1 of 6 subrecipients selected for testing, subaward monitoring was not completed in accordance with the Department’s policy. • For 1 of 6 subrecipients selected for testing, a determination on whether the entity was a subrecipient was unable to be made based on the documentation provided. • One subrecipient was excluded from subrecipient testing based on auditor analysis that the entity did not meet the definition of a subrecipient. The Schedule of Expenditures of Federal Awards was not adjusted to reflect the classification change. Employment Service Cluster: Five out of sixteen subrecipients were selected for testing. The following exceptions were noted: • For 5 of 5 subawards issued, the Federal Award Identification Number (FAIN) and the Federal award date of award to the recipient by the Federal agency were not included on the subaward agreement. Cause: The Department’s procedures were not sufficient to ensure that subawards included all required information nor that subrecipient monitoring was completed in accordance with the requirements of the federal programs. Effect: Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Failure to conduct adequate subrecipient monitoring may result in a failure of the Department to detect that subawards were used for unauthorized purposes, were managed in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. There is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Department personnel on a timely basis. Questioned costs: WIOA Cluster: Undetermined Employment Service Cluster: None Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that required information is included in its subawards. We also recommend the Department review and enhance its internal controls and procedures to ensure subrecipient monitoring is performed in compliance with the requirements of the federal programs. Views of Responsible Officials: Management agrees with the finding.