SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
Finding 2024-003: SEFA Preparation— Subrecipient vs. Subcontractor Determinations Federal Program(s): • Adv HIV & AIDS Epidemic Control (AHEC) Activity - ALN 98.U01 • ASAP & ASAP II – ALN 98.U02 • Zambia Local – ALN 98.U03 Criteria: The auditee must prepare the financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510 (2 CFR 200.508 (b)). The SEFA must include the total amount provided to subrecipients from each Federal program (2 CFR 200.510 (b)(4)). Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the SEFA. Cause: Ineffective design and implementation of internal controls around SEFA preparation. Effect: There were approximately $2.6 million in subcontractor expenses incurred by IntraHealth that were improperly included in the Amounts to Subrecipients column on the SEFA as they did not represent payments to subrecipients. Questioned costs: None Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Repeat finding: No Recommendation: We recommend that management review internal controls in place around the SEFA preparation and ensure an independent review is being performed around amounts reported as Amounts to Subrecipients against 2 CFR 200.331, Subrecipient and subcontractor determinations. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2024-003: SEFA Preparation— Subrecipient vs. Subcontractor Determinations Federal Program(s): • Adv HIV & AIDS Epidemic Control (AHEC) Activity - ALN 98.U01 • ASAP & ASAP II – ALN 98.U02 • Zambia Local – ALN 98.U03 Criteria: The auditee must prepare the financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510 (2 CFR 200.508 (b)). The SEFA must include the total amount provided to subrecipients from each Federal program (2 CFR 200.510 (b)(4)). Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the SEFA. Cause: Ineffective design and implementation of internal controls around SEFA preparation. Effect: There were approximately $2.6 million in subcontractor expenses incurred by IntraHealth that were improperly included in the Amounts to Subrecipients column on the SEFA as they did not represent payments to subrecipients. Questioned costs: None Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Repeat finding: No Recommendation: We recommend that management review internal controls in place around the SEFA preparation and ensure an independent review is being performed around amounts reported as Amounts to Subrecipients against 2 CFR 200.331, Subrecipient and subcontractor determinations. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2024-003: SEFA Preparation— Subrecipient vs. Subcontractor Determinations Federal Program(s): • Adv HIV & AIDS Epidemic Control (AHEC) Activity - ALN 98.U01 • ASAP & ASAP II – ALN 98.U02 • Zambia Local – ALN 98.U03 Criteria: The auditee must prepare the financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510 (2 CFR 200.508 (b)). The SEFA must include the total amount provided to subrecipients from each Federal program (2 CFR 200.510 (b)(4)). Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the SEFA. Cause: Ineffective design and implementation of internal controls around SEFA preparation. Effect: There were approximately $2.6 million in subcontractor expenses incurred by IntraHealth that were improperly included in the Amounts to Subrecipients column on the SEFA as they did not represent payments to subrecipients. Questioned costs: None Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Repeat finding: No Recommendation: We recommend that management review internal controls in place around the SEFA preparation and ensure an independent review is being performed around amounts reported as Amounts to Subrecipients against 2 CFR 200.331, Subrecipient and subcontractor determinations. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2024-003: SEFA Preparation— Subrecipient vs. Subcontractor Determinations Federal Program(s): • Adv HIV & AIDS Epidemic Control (AHEC) Activity - ALN 98.U01 • ASAP & ASAP II – ALN 98.U02 • Zambia Local – ALN 98.U03 Criteria: The auditee must prepare the financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510 (2 CFR 200.508 (b)). The SEFA must include the total amount provided to subrecipients from each Federal program (2 CFR 200.510 (b)(4)). Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the SEFA. Cause: Ineffective design and implementation of internal controls around SEFA preparation. Effect: There were approximately $2.6 million in subcontractor expenses incurred by IntraHealth that were improperly included in the Amounts to Subrecipients column on the SEFA as they did not represent payments to subrecipients. Questioned costs: None Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Repeat finding: No Recommendation: We recommend that management review internal controls in place around the SEFA preparation and ensure an independent review is being performed around amounts reported as Amounts to Subrecipients against 2 CFR 200.331, Subrecipient and subcontractor determinations. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding Number: 2024-008 Prior Year Finding Number: 2023-015 Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 – 09/20/2024 Government Department/Agency: Office of the Deputy Mayor for Public Safety and Justice (DMPSJ); Office of Neighborhood Safety and Engagement (ONSE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the Uniform Guidance in 2 CFR Section 200.331(a) Requirements for Pass-Through Entities requires that pass-through entities must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information outlined in the section noted above, pre-award assessment, indirect cost rated for the award, assistance listing number, finding and award follow-up and other pertinent actions. In accordance with the Uniform Guidance in 2 CFR Section 200.332 Requirements for Pass-Through Entities requires that pass-through entities Verify that the subrecipient is not excluded or disqualified in accordance with Section 180.300. Verification methods are provided in Section 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. In accordance with the Uniform Guidance in 2 CFR Section 200.332(e) Requirements for Pass-Through Entities requires that pass-through entities must: Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: • Review financial and performance reports • Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. • Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521. • Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section Section 200.513(a)(4)(viii). 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. Condition – The program’s documented subrecipient monitoring requirements includes risk assessments, monitoring of subrecipients and the submission and review of monthly financial and performance reports. During our testing of the subrecipient’s compliance requirements, we noted the following issues: • Our testing of the program’s subrecipient monitoring requirements includes submission and review of monthly financial and performance reports. We noted for one (1) out of 17 samples, the subrecipient failed to submit their monthly financial and performance reports. • For one (1) out of 17 samples, the agency had no evidence to support it had performed the mandatory follow up on reported audit findings in the subrecipient’s audit report for the Corrective Action taken by the subrecipient to remediate the finding. • For one (1) out of 17 samples, the agency had no evidence that a debarment check was performed before the contract was entered into. The agency’s documented policies and the procurement procedures mandate a debarment check before entering into new contracts. Questioned Costs – Not determinable. Context – This is a condition identified per review of various District agencies’ compliance with specified monitoring requirements on the program’s subrecipients using a statistically valid sample. Effect – Subrecipients may not be properly monitored, which may result in subawards being used for unauthorized purposes in violation of the terms and conditions of the subawards or that the subaward performance goals were not achieved. Cause – There is lack of sufficient documentary evidence to support that the controls are operating as designed related to subrecipient monitoring compliance. Recommendation – We recommend that the agencies maintain sufficient documentation to evidence its internal controls over the risk assessment and monitoring of subrecipients. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – While DMPSJ doesn’t agree that it is out of compliance, DMPSJ will ensure documentation is maintained regarding its oversight of grant management. ONSE acknowledges and accepts the finding that the subrecipient failed to submit their monthly and performance reports. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section. BDO’s Response – We have reviewed management’s response and our finding remains as indicated.
Federal Program: AL 11.307 – Economic Adjustment Assistance Criteria: Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (The Chamber Foundation) must perform certain activities to ensure that the subrecipient uses funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes review of independent audits of subrecipients and response to deficiencies detected through audits (2 CFR section 200.331(f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition: For the year ended August 31, 2024, we reviewed the Foundation’s subrecipient internal controls, requesting supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Unform Guidance for subrecipient monitoring and per the Foundation’s internal controls could not be substantiated or were determined to not have occurred during the year under audit. Cause: Due to internal control deficiency noted in 2024-002, the subrecipient monitoring requirement was not in compliance during the year. Context: Of the federal expenditures under the program noted, $341,811 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with the Chamber Foundation staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the four subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the four subawards awarded to pass-through entities, one was missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient’s unique entity identifier. Effect: Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Questioned costs: None Indication of Repeat Finding: This is not a repeat finding. Recommendation: The Foundation should request yearly audit reports as determined by 2 CFR 2002. Additionally, the entity should include all required information as determined in CFR Section 200.331(a) in all subawards. Views of Responsible Officials: Management recognizes the deficiency and plans to implement the auditor’s recommendations.
Federal Program: AL 11.307 – Economic Adjustment Assistance Criteria: Uniform Guidance requires, for any funds passed through to a subrecipient, that the pass-through entity (The Chamber Foundation) must perform certain activities to ensure that the subrecipient uses funds within provisions of the grant award and Uniform Guidance (2 CFR sections 200.331 (d) through (f)). This includes review of independent audits of subrecipients and response to deficiencies detected through audits (2 CFR section 200.331(f)). It also includes requiring all subawards granted to subrecipients have specific identifications with the award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)). Condition: For the year ended August 31, 2024, we reviewed the Foundation’s subrecipient internal controls, requesting supporting documentation for monitoring activities included, and interviewed key members of management when documentation was not available. Performance of several of the policies noted as required under Unform Guidance for subrecipient monitoring and per the Foundation’s internal controls could not be substantiated or were determined to not have occurred during the year under audit. Cause: Due to internal control deficiency noted in 2024-002, the subrecipient monitoring requirement was not in compliance during the year. Context: Of the federal expenditures under the program noted, $341,811 are passed through to subrecipients. The following are specific items noted that were not in compliance with the criteria listed above: - We requested copies of the correspondence with subrecipients requesting copies of the financial statement audits performed in compliance with 2 CFR 200. Follow up discussion with the Chamber Foundation staff confirmed that this requirement was not completed during the year under audit. Subsequently, of the four subrecipient audit reports required to be requested, zero were requested. - We requested copies of all subawards awarded to subrecipients. Of the four subawards awarded to pass-through entities, one was missing the following required information under (2 CFR Section 200.331(a)): o Subrecipient’s unique entity identifier. Effect: Increased risk of potential noncompliance with subrecipient monitoring requirements under Uniform Guidance. Questioned costs: None Indication of Repeat Finding: This is not a repeat finding. Recommendation: The Foundation should request yearly audit reports as determined by 2 CFR 2002. Additionally, the entity should include all required information as determined in CFR Section 200.331(a) in all subawards. Views of Responsible Officials: Management recognizes the deficiency and plans to implement the auditor’s recommendations.
U.S. Department of Health and Human Services Family Planning Services AL #93.217 Award No. FPHPA006563, FPHPA006619 Criteria: 2 CFR 200.331 requires that pass‐through entities disbursing federal funds to subrecipients have a formalized policy for identifying the subrecipient meets the applicable requirements, for evaluating risk, for monitoring subrecipient activity, and for ensuring accountability of For‐Profit Subrecipients, if applicable. Additionally, certain information regarding the federal award is required to be communicated to the subrecipient. During monitoring activities, the pass‐through entity is required to obtain the subrecipient’s audit reports so any findings can be evaluated by the pass‐through entity’s management. Condition: The Organization does not have a formalized policy. Additionally, the subrecipient agreements were missing required information and audit report findings were not reviewed and followed‐up on. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Certain compliance elements related to subrecipient monitoring were not met as a result of ineffective controls. Questioned Costs: None Context/Sampling: There were 11 subrecipients during the year, of which 3 were selected for review. Repeat Finding from Prior Year: No Recommendation: Management should implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332 and update the subrecipient agreements to include all required information. Additionally, audit findings should be followed up on. Views of Responsible Officials: Management agrees with this finding.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-002 - Subrecipient Monitoring Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Subrecipient Monitoring). Federal program(s) U.S. Department of Treasury - COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) (ALN 21.027); Passed through Michigan Strategic Fund; Award Number 398728. Criteria. A pass-through entity must monitor the activities of the subrecipients 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 200.331(d)-(f)), plus any additional items identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award. Condition. We noted that the Organization did not compile any risk assessments or perform adequate subrecipient monitoring during the fiscal year. Cause. The cause of this condition appears to be a lack of understanding of the subrecipient monitoring requirements of the grants. Effect. The lack of monitoring failed to provide reasonable assurance that the subrecipients complied with the provisions of the grant. Questioned Costs. No costs were questioned due to the fact that the Organization approved subrecipient expenditures. Recommendation. We recommend that the Organization create a subrecipient policy to ensure that all subrecipient grant awards are monitored in compliance with the Uniform Guidance requirements. View of Responsible Officials. Management is in agreement and has prepared a Corrective Action Plan.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
2024-087: Review Subrecipient Audit Reports Applicable to: Department of Health Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency Information System Security Control Family: N/A ALPT or Cluster Name and ALN: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) - 93.323; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises - 93.391 Federal Award Number and Year: Various - 2024 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR § 200.331(d) Known Questioned Costs: $0 Health does not monitor subrecipients in accordance with federal regulations for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises federal grant programs. During our audit, we found that Health’s Office of Epidemiology (Epidemiology) and the Office of Health Equity (OHE) did not obtain and review a Single Audit or program-specific audit report for subrecipients who received $750,000 or more in subawards from ELC and STLT funds. During fiscal year 2024, Health disbursed approximately $11 million in ELC funds and $5.8 million in STLT funds to subrecipients. According to Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that the subrecipient’s federal awards expended during the respective fiscal year will equal or exceed $750,000. Additionally, in the case of any findings, 2 CFR § 200.332(d)(3) requires pass-through entities to issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (Clearinghouse). Due to significant turnover in contract administrators responsible for subrecipient monitoring, Epidemiology and OHE were unable to provide evidence that staff reviewed Single Audit or program-specific audit reports for all subrecipients expending $750,000 or more during fiscal year 2024. In addition, OFM did not have a current subrecipient monitoring policy and procedure in place to detect subrecipients that met the audit threshold. Health last updated its subrecipient monitoring policy in 2014. Without obtaining the appropriate reports, Health is unable to show it is meeting the requirements set forth in 2 CFR part 200, subpart F, which includes issuing a management decision on audit findings within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. OFM should update its subrecipient monitoring policy and communicate the policy to the applicable offices and districts. In addition, OFM should periodically review the Clearinghouse to determine whether subrecipients who meet the audit threshold obtain the required audits, and that the applicable offices or districts are reviewing the audit reports and considering the impact of any deficiencies identified in audit findings. Epidemiology and OHE should ensure staff review Single Audit or program-specific audit reports for subrecipients who meet the audit threshold and should adhere to all federal requirements when conducting monitoring over such subrecipients. Views of Responsible Officials: The views of responsible officials are included in the report related to their applicable organization, which can be found at www.apa.virginia.gov and, in summary, do not express disagreement with the finding.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all 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 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. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used. Per 2 CFR 200.303, non-federal entities receiving federal awards 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: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information. Questioned costs: None. Context: Fifteen of fifteen subawards selected for testing, totaling $2,661,654, did not include all required federal award information. Specifically, the following was omitted: • Assistance Listing Number and Program Title • Subrecipient’s Unique Identifier • Federal Award Identification Number (FAIN) • Identification of whether the award is research and development • Indirect cost rate for federal award Cause: The Department’s procedures were not sufficient to ensure that subawards included all required federal award information. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal award information at the time of subaward issuance could result in subrecipients not properly administering the federal programs in accordance with federal regulations. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports when all federal award information is not provided to them. Repeat Finding: Yes, finding 2023-007. Recommendation: We recommend that the Department develop a subaward template that includes all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. Views of responsible officials: Management disagrees with the finding. Multi-year subrecipient agreements executed prior to March 2024 did not include the Sub-Recipient Agreement Submission Form. The agreements were not re-executed after March 2024 to include the form. The audit findings should only pertain to agreements newly executed after March 2024; however, because the audit included agreements executed prior to March 2024, the audit found that information is missing. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of that the missing information from the subawards occurring prior to or the same time as the subaward being entered into was not provided.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all 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 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. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used. Per 2 CFR 200.303, non-federal entities receiving federal awards 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: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information. Questioned costs: None. Context: Fifteen of fifteen subawards selected for testing, totaling $2,661,654, did not include all required federal award information. Specifically, the following was omitted: • Assistance Listing Number and Program Title • Subrecipient’s Unique Identifier • Federal Award Identification Number (FAIN) • Identification of whether the award is research and development • Indirect cost rate for federal award Cause: The Department’s procedures were not sufficient to ensure that subawards included all required federal award information. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal award information at the time of subaward issuance could result in subrecipients not properly administering the federal programs in accordance with federal regulations. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports when all federal award information is not provided to them. Repeat Finding: Yes, finding 2023-007. Recommendation: We recommend that the Department develop a subaward template that includes all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. Views of responsible officials: Management disagrees with the finding. Multi-year subrecipient agreements executed prior to March 2024 did not include the Sub-Recipient Agreement Submission Form. The agreements were not re-executed after March 2024 to include the form. The audit findings should only pertain to agreements newly executed after March 2024; however, because the audit included agreements executed prior to March 2024, the audit found that information is missing. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of that the missing information from the subawards occurring prior to or the same time as the subaward being entered into was not provided.
Criteria or specific requirement: Per 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information listed in 2 CFR 200.332(a)(1) 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. Per 2 CFR 200.331(b), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required award information. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: Subrecipient's name, Subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), Federal Award Date, Subaward Period of Performance Start and End Date, Subaward Budget Period Start and End Date, Amount of Federal Funds Obligated in the subaward, Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation, Total Amount of the Federal Award committed to the subrecipient by the pass-through entity, Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA), Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity, Assistance Listings title and number, Identification of whether the Federal award is for research and development, Indirect cost rate for the Federal award (including if the de minimis rate is used. Per 2 CFR 200.303, non-federal entities receiving federal awards 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: Kansas Division of Emergency Management (Management) did not issue subawards to subrecipients until after the fiscal year ended. Questioned costs: None. Context: For 22 of 22 subrecipients selected for testing, Management did not issue subawards until after the fiscal year ended. Cause: 2 CFR 200.332(a) requires subawards to include certain required information to be communicated to subrecipients at the time of the subaward being awarded. The subaward information was not communicated to subrecipients under after the fiscal year ended June 30, 2024, and should have been communicated at the time the subawards were awarded during the fiscal year subject to audit. Effect: Failure to issue subawards timely and to include required federal award information could result in subrecipients not properly administering the federal program in accordance with federal regulations. Repeat Finding: No. Recommendation: We recommend that Management reviews and enhances its internal controls and procedures to ensure that subawards are issued timely to subrecipients, and that subawards that include all required federal award information is communicated at the time of the subaward. Views of responsible officials: Management partially agrees with this finding. Although the 2023 2 CFR § 200.332 does state that the award letters should be sent at the time of the award, there needs to be some reasonableness to the interpretation of this regulation. KDEM currently has 13 open disasters with over 100 open projects and more being written. It is not reasonable to interpret that the award letters be sent on the date that the award is granted. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence that the required information per 2 CFR 200.332 being provided to subrecipients at the time of the subawards was not provided.