Finding number: 2022 006 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that 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. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) was unable to provide documentation for one of the 8 subrecipients showing that a formal risk evaluation had been performed. In addition, the Age Strong Commission?s internal controls did not include formal risk evaluation procedures. Cause This appears to be due to inadequate policies and procedures surrounding the initial risk assessment of the subrecipients. Effect The Age Strong Commission does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that the Age Strong Commission implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. View of Responsible Officials from the Auditee A risk assessment questionnaire will be completed prior to funding being awarded to a sub recipient. The City of Boston?s Age Strong Commission?s policies and procedures will be updated to reflect this.
Finding number: 2022 005 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates 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: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass through entity, and contact information for awarding official of the pass through entity; ? ALN Number and Name; the pass through entity must identify the dollar amount made available under each Federal award and the ALN number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) 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. (3) 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; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) subaward letters were authorized however it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For all 8 subrecipients, the subaward letter did not identify whether the subaward is R&D and did not contain the indirect cost rate for the Federal award. Cause This appears to be due to inadequate review to ensure the subaward includes all of the required elements of 2CFR Section 200.331(a) prior to authorization. Effect Aging does not have adequate controls over subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM execute an updated MOA with its subrecipients that expressly includes all information description in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate.
Finding number: 2022 006 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that 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. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) was unable to provide documentation for one of the 8 subrecipients showing that a formal risk evaluation had been performed. In addition, the Age Strong Commission?s internal controls did not include formal risk evaluation procedures. Cause This appears to be due to inadequate policies and procedures surrounding the initial risk assessment of the subrecipients. Effect The Age Strong Commission does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that the Age Strong Commission implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. View of Responsible Officials from the Auditee A risk assessment questionnaire will be completed prior to funding being awarded to a sub recipient. The City of Boston?s Age Strong Commission?s policies and procedures will be updated to reflect this.
Finding number: 2022 005 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates 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: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass through entity, and contact information for awarding official of the pass through entity; ? ALN Number and Name; the pass through entity must identify the dollar amount made available under each Federal award and the ALN number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) 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. (3) 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; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) subaward letters were authorized however it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For all 8 subrecipients, the subaward letter did not identify whether the subaward is R&D and did not contain the indirect cost rate for the Federal award. Cause This appears to be due to inadequate review to ensure the subaward includes all of the required elements of 2CFR Section 200.331(a) prior to authorization. Effect Aging does not have adequate controls over subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM execute an updated MOA with its subrecipients that expressly includes all information description in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate.
Finding number: 2022 006 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that 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. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) was unable to provide documentation for one of the 8 subrecipients showing that a formal risk evaluation had been performed. In addition, the Age Strong Commission?s internal controls did not include formal risk evaluation procedures. Cause This appears to be due to inadequate policies and procedures surrounding the initial risk assessment of the subrecipients. Effect The Age Strong Commission does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that the Age Strong Commission implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. View of Responsible Officials from the Auditee A risk assessment questionnaire will be completed prior to funding being awarded to a sub recipient. The City of Boston?s Age Strong Commission?s policies and procedures will be updated to reflect this.
Finding number: 2022 007 Federal agency: U.S. Department of Homeland Security Pass through agency: Massachusetts Executive Office of Public Safety & Security Program: Homeland Security Grant Program ALN #: 97.067 Award number: Boston FFY 19 UASI, Boston FFY 20 UASI, Boston FFY 21 UASI, Boston FFY 22 UASI, Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria According to 2 CFR 200.331 (b), a pass through entity must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: ? The subrecipient?s prior experience with the same or similar subawards; ? The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; ? Whether the subrecipient has new personnel or new or substantially changed systems; and ? The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Also, according to 2 CFR 200.331 (d), a pass through entity must: ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. ? Follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on site reviews, and other means. Additionally, 2 CFR 200.303 indicates that 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. Condition Based on our testwork, it was noted that the Mayor?s Office of Office of Emergency Management (OEM) did not perform a formal evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring to be performed. Further, our review of program monitoring documentation for our sample of 4 of the population of 11 subrecipients indicated that, although OEM performed subrecipient monitoring in fiscal year 2022, OEM did not follow up with 2 out of 4 subrecipients as to why the amount of total program expenditures on the subrecipients? fiscal year 2021 Schedule of Expenditures of Federal Awards (SEFA) were different than total program expenditures reported to them by OEM. Cause This appears to be due to inadequate policies and procedures surrounding both the initial risk assessment of the subrecipients, as well as follow up with subrecipients when differences are noted between funding amounts reported to the subrecipient by OEM and amounts reported of the subrecipient?s SEFA. Effect OEM does not have adequate controls over evaluating each subrecipient?s risk of noncompliance for purposes of determining appropriate subrecipient monitoring, and ensuring that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM implement control procedures to ensure that each subrecipient is evaluated for risk of noncompliance for determining appropriate subrecipient monitoring, and to ensure that the total amount of expenditures reported on the subrecipient?s SEFA is consistent with grant funding provided by OEM to the subrecipient. View of Responsible Officials from the Auditee OEM will add an event to the departmental annual calendar on the first business day of the month of May of every year indicating that pre risk assessment forms for the upcoming fiscal year beginning on July 1st are to be sent out to subrecipients of federal funds. The addition of this even to the calendar will ensure that all appropriate Admin and Finance staff at OEM are aware of this annual requirement and follow up with subrecipients to receive completed pre risk assessments in advance of the new fiscal year. OEM?s Director of Admin and Finance will be the primary point of contact for pre risk assessment related inquiries from subrecipients, with the Assistant Deputy Chief of Administration serving as a backup point of contact. An event will also be added on the final business day of May each year to ensure that OEM staff follow up with subrecipients that were not responsive to the initial request. OEM will also institute a policy of requiring a written response following receipt of a SEFA letter from OEM detailing the previous fiscal year?s expenditures on behalf of a subrecipient. This written response will contain confirmation that the subrecipients have recorded the same expenditures in their accounting systems as OEM reported in the SEFA letter. Should there be any discrepancy between the information provided in the SEFA from OEM and the expenditures reported by the subrecipient, OEM will schedule a meeting to reconcile any differences and resolve discrepancies within 30 days of being notified of said discrepancies. The Director of Admin and Finance and the Assistant Deputy Chief of Administration will represent OEM in this meeting with the appropriate staff from the subrecipient reporting a discrepancy. Confirmation of resolution of any discrepancies will be documented in writing and attached to SEFA letters for record keeping purposes.
2022-001 ? Subrecipient Monitoring U.S. Department of Health and Human Services AL #93.421 Vaccine Ambassador Program Federal Grantor/ Pass-Through Grantor Grant Number Grant Period National Association of N/A 09/01/21 ? 12/30/22 Community Health Centers, Inc. Questioned costs: None How the questioned costs were computed: Not applicable Condition: NHCHC did not report subaward information to the subrecipient as required by 2 CFR section 200.331(a)(1). Criteria: Federal Regulation 2 CFR Section 200.331(a)(1) requires that subaward documents, including terms and conditions of the subaward, are provided to the subrecipients so they are aware of the award information to comply with federal statutes, regulations, and terms and conditions of the award. Cause: Management was unaware of the subrecipient monitoring requirements when NHCHC made subgrant awards and did not include the required information in the subgrant awards. Effect: Because of the above condition, NHCHC was not in compliance with this compliance requirement and a material weakness in internal controls over compliance exists. Recommendation: We recommend that NHCHC establish procedures to ensure it is aware of all terms and conditions of its grant awards and includes the required information in its subgrant awards. View of responsible official: Management agrees with the assessment and has committed to a corrective action plan.
2022-002 (Previously 2021-001) Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Federal Program Title: Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Homevisiting Assistance Listing Numbers: 93.575/596 and 93.870 Pass-Through Agency: 93.596 ? Passed through NM Department of Human Services ? 22-630-9000- 0005 Federal Award Identification Number and Year: 93.596: 22-630-9000-0005 -7/1/21-06/30/2022 2102 CCDF ? 10/1/2020-09/30/2023 93.870: X10MC43597 - 9/1/2021-9/29/23 X10MC39703 - 9/30/2020-9/29/2022 X11MC41939 -05/01/21-09/30/23 6X11MC45479-01-02 - 12/31/21-9/30/24 Type of Finding: Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) Condition: During our testing, we noted the following: 93.596: -2 of the 3 subrecipients identified did not have adequate documentation of formal financial monitoring activities during the year. The program did provide support for programmatic monitoring. - Additionally, the agreements did not contain language regarding suspension and debarment. -2 of the 3 applicable subrecipients tested did not have related FFATA reporting documentation, nor was there documentation provided to support a risk assessment process was undertaken prior to selecting these entities as subrecipients. 93.870: -For 3 out of 3 potential subrecipients, the Program has agreements with entities that identify subaward arrangements, but the program was not performing programmatic or financial monitoring procedures. Management?s response towards implementing prior-year corrective action plan: ECECD program managers began to perform financial monitoring in the form of reviews of federal audit reports, reviews of subrecipient single audits and reviewed general ledger outputs to determine proper PO creation and project ID tracking for PreK awards in FY `22. We also had identification of program elements related to management control (key stakeholder turnover, and system shocks) with program staff after feedback from our internal audit. ECECD is not certain about the status of subrecipient monitoring in other areas of the agency, however PreK program made great strides in remediation in this area for private and public PreK.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Condition (Continued): PreK has created draft policies and procedures for subrecipient monitoring at the program level that address allowability, financial monitoring, risk determinations. These policies and procedures are being reviewed for agency wide implementation for our grants compliance internal audit. These procedures are currently in use while we await approval by ASD and Executive Management. PreK also created a single guidance document and passed that out to all PreK stakeholders outlining allowability of expenditures that is a living document but I have attached this information here. This was developed and implemented with stakeholder training after our PreK internal audit identified this as an issue. Criteria or Specific Requirement: Per 2 CFR ?200.331 Requirements for pass-through entities, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Passthrough entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity. Additionally, ?200.331(a) includes required elements that are to be included in the subawards. Questioned Costs: none Context: This was identified during our testing of the respective samples selected for subrecipient monitoring. See condition above. Cause: Lack of thorough communication between program and ASD staff regarding language to be included in subawards. Additionally, lack of emphasis placed on financial monitoring; focus is on programmatic monitoring. Additionally, with regarding to 93.870, current program personnel did not believe the entities qualified as a subrecipient and have communication from the federal agent to support that determination. However, current program personnel were unaware that the agreement between the Department and the entity identified the entity as a subrecipient because the determination was made by program personnel that did not have adequate experience with determination of subrecipients. Effect: The Department is not compliance with Federal Regulations. Repeat Finding: Yes Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Views of Responsible Officials: The Early Childhood Education and Care Department (ECECD) agrees with this audit finding and the Family Support and Early Intervention Division (FSEI) agrees with the recommendation that the Department could benefit from improved processes. To ensure this does not occur again, the FSEI Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FESI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FESI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. The timeline is June 30, 2023.
2022-002 (Previously 2021-001) Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Federal Program Title: Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Homevisiting Assistance Listing Numbers: 93.575/596 and 93.870 Pass-Through Agency: 93.596 ? Passed through NM Department of Human Services ? 22-630-9000- 0005 Federal Award Identification Number and Year: 93.596: 22-630-9000-0005 -7/1/21-06/30/2022 2102 CCDF ? 10/1/2020-09/30/2023 93.870: X10MC43597 - 9/1/2021-9/29/23 X10MC39703 - 9/30/2020-9/29/2022 X11MC41939 -05/01/21-09/30/23 6X11MC45479-01-02 - 12/31/21-9/30/24 Type of Finding: Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) Condition: During our testing, we noted the following: 93.596: -2 of the 3 subrecipients identified did not have adequate documentation of formal financial monitoring activities during the year. The program did provide support for programmatic monitoring. - Additionally, the agreements did not contain language regarding suspension and debarment. -2 of the 3 applicable subrecipients tested did not have related FFATA reporting documentation, nor was there documentation provided to support a risk assessment process was undertaken prior to selecting these entities as subrecipients. 93.870: -For 3 out of 3 potential subrecipients, the Program has agreements with entities that identify subaward arrangements, but the program was not performing programmatic or financial monitoring procedures. Management?s response towards implementing prior-year corrective action plan: ECECD program managers began to perform financial monitoring in the form of reviews of federal audit reports, reviews of subrecipient single audits and reviewed general ledger outputs to determine proper PO creation and project ID tracking for PreK awards in FY `22. We also had identification of program elements related to management control (key stakeholder turnover, and system shocks) with program staff after feedback from our internal audit. ECECD is not certain about the status of subrecipient monitoring in other areas of the agency, however PreK program made great strides in remediation in this area for private and public PreK.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Condition (Continued): PreK has created draft policies and procedures for subrecipient monitoring at the program level that address allowability, financial monitoring, risk determinations. These policies and procedures are being reviewed for agency wide implementation for our grants compliance internal audit. These procedures are currently in use while we await approval by ASD and Executive Management. PreK also created a single guidance document and passed that out to all PreK stakeholders outlining allowability of expenditures that is a living document but I have attached this information here. This was developed and implemented with stakeholder training after our PreK internal audit identified this as an issue. Criteria or Specific Requirement: Per 2 CFR ?200.331 Requirements for pass-through entities, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Passthrough entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity. Additionally, ?200.331(a) includes required elements that are to be included in the subawards. Questioned Costs: none Context: This was identified during our testing of the respective samples selected for subrecipient monitoring. See condition above. Cause: Lack of thorough communication between program and ASD staff regarding language to be included in subawards. Additionally, lack of emphasis placed on financial monitoring; focus is on programmatic monitoring. Additionally, with regarding to 93.870, current program personnel did not believe the entities qualified as a subrecipient and have communication from the federal agent to support that determination. However, current program personnel were unaware that the agreement between the Department and the entity identified the entity as a subrecipient because the determination was made by program personnel that did not have adequate experience with determination of subrecipients. Effect: The Department is not compliance with Federal Regulations. Repeat Finding: Yes Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Views of Responsible Officials: The Early Childhood Education and Care Department (ECECD) agrees with this audit finding and the Family Support and Early Intervention Division (FSEI) agrees with the recommendation that the Department could benefit from improved processes. To ensure this does not occur again, the FSEI Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FESI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FESI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. The timeline is June 30, 2023.
2022-002 (Previously 2021-001) Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Federal Program Title: Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Homevisiting Assistance Listing Numbers: 93.575/596 and 93.870 Pass-Through Agency: 93.596 ? Passed through NM Department of Human Services ? 22-630-9000- 0005 Federal Award Identification Number and Year: 93.596: 22-630-9000-0005 -7/1/21-06/30/2022 2102 CCDF ? 10/1/2020-09/30/2023 93.870: X10MC43597 - 9/1/2021-9/29/23 X10MC39703 - 9/30/2020-9/29/2022 X11MC41939 -05/01/21-09/30/23 6X11MC45479-01-02 - 12/31/21-9/30/24 Type of Finding: Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) Condition: During our testing, we noted the following: 93.596: -2 of the 3 subrecipients identified did not have adequate documentation of formal financial monitoring activities during the year. The program did provide support for programmatic monitoring. - Additionally, the agreements did not contain language regarding suspension and debarment. -2 of the 3 applicable subrecipients tested did not have related FFATA reporting documentation, nor was there documentation provided to support a risk assessment process was undertaken prior to selecting these entities as subrecipients. 93.870: -For 3 out of 3 potential subrecipients, the Program has agreements with entities that identify subaward arrangements, but the program was not performing programmatic or financial monitoring procedures. Management?s response towards implementing prior-year corrective action plan: ECECD program managers began to perform financial monitoring in the form of reviews of federal audit reports, reviews of subrecipient single audits and reviewed general ledger outputs to determine proper PO creation and project ID tracking for PreK awards in FY `22. We also had identification of program elements related to management control (key stakeholder turnover, and system shocks) with program staff after feedback from our internal audit. ECECD is not certain about the status of subrecipient monitoring in other areas of the agency, however PreK program made great strides in remediation in this area for private and public PreK.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Condition (Continued): PreK has created draft policies and procedures for subrecipient monitoring at the program level that address allowability, financial monitoring, risk determinations. These policies and procedures are being reviewed for agency wide implementation for our grants compliance internal audit. These procedures are currently in use while we await approval by ASD and Executive Management. PreK also created a single guidance document and passed that out to all PreK stakeholders outlining allowability of expenditures that is a living document but I have attached this information here. This was developed and implemented with stakeholder training after our PreK internal audit identified this as an issue. Criteria or Specific Requirement: Per 2 CFR ?200.331 Requirements for pass-through entities, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Passthrough entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity. Additionally, ?200.331(a) includes required elements that are to be included in the subawards. Questioned Costs: none Context: This was identified during our testing of the respective samples selected for subrecipient monitoring. See condition above. Cause: Lack of thorough communication between program and ASD staff regarding language to be included in subawards. Additionally, lack of emphasis placed on financial monitoring; focus is on programmatic monitoring. Additionally, with regarding to 93.870, current program personnel did not believe the entities qualified as a subrecipient and have communication from the federal agent to support that determination. However, current program personnel were unaware that the agreement between the Department and the entity identified the entity as a subrecipient because the determination was made by program personnel that did not have adequate experience with determination of subrecipients. Effect: The Department is not compliance with Federal Regulations. Repeat Finding: Yes Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Views of Responsible Officials: The Early Childhood Education and Care Department (ECECD) agrees with this audit finding and the Family Support and Early Intervention Division (FSEI) agrees with the recommendation that the Department could benefit from improved processes. To ensure this does not occur again, the FSEI Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FESI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FESI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. The timeline is June 30, 2023.
2022-002 (Previously 2021-001) Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Federal Program Title: Child Care Development Fund Block Grant and Maternal, Infant, Early Childhood Homevisiting Assistance Listing Numbers: 93.575/596 and 93.870 Pass-Through Agency: 93.596 ? Passed through NM Department of Human Services ? 22-630-9000- 0005 Federal Award Identification Number and Year: 93.596: 22-630-9000-0005 -7/1/21-06/30/2022 2102 CCDF ? 10/1/2020-09/30/2023 93.870: X10MC43597 - 9/1/2021-9/29/23 X10MC39703 - 9/30/2020-9/29/2022 X11MC41939 -05/01/21-09/30/23 6X11MC45479-01-02 - 12/31/21-9/30/24 Type of Finding: Material Weakness in Internal Control and Material Noncompliance (Modified Opinion) Condition: During our testing, we noted the following: 93.596: -2 of the 3 subrecipients identified did not have adequate documentation of formal financial monitoring activities during the year. The program did provide support for programmatic monitoring. - Additionally, the agreements did not contain language regarding suspension and debarment. -2 of the 3 applicable subrecipients tested did not have related FFATA reporting documentation, nor was there documentation provided to support a risk assessment process was undertaken prior to selecting these entities as subrecipients. 93.870: -For 3 out of 3 potential subrecipients, the Program has agreements with entities that identify subaward arrangements, but the program was not performing programmatic or financial monitoring procedures. Management?s response towards implementing prior-year corrective action plan: ECECD program managers began to perform financial monitoring in the form of reviews of federal audit reports, reviews of subrecipient single audits and reviewed general ledger outputs to determine proper PO creation and project ID tracking for PreK awards in FY `22. We also had identification of program elements related to management control (key stakeholder turnover, and system shocks) with program staff after feedback from our internal audit. ECECD is not certain about the status of subrecipient monitoring in other areas of the agency, however PreK program made great strides in remediation in this area for private and public PreK.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Condition (Continued): PreK has created draft policies and procedures for subrecipient monitoring at the program level that address allowability, financial monitoring, risk determinations. These policies and procedures are being reviewed for agency wide implementation for our grants compliance internal audit. These procedures are currently in use while we await approval by ASD and Executive Management. PreK also created a single guidance document and passed that out to all PreK stakeholders outlining allowability of expenditures that is a living document but I have attached this information here. This was developed and implemented with stakeholder training after our PreK internal audit identified this as an issue. Criteria or Specific Requirement: Per 2 CFR ?200.331 Requirements for pass-through entities, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Passthrough entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity. Additionally, ?200.331(a) includes required elements that are to be included in the subawards. Questioned Costs: none Context: This was identified during our testing of the respective samples selected for subrecipient monitoring. See condition above. Cause: Lack of thorough communication between program and ASD staff regarding language to be included in subawards. Additionally, lack of emphasis placed on financial monitoring; focus is on programmatic monitoring. Additionally, with regarding to 93.870, current program personnel did not believe the entities qualified as a subrecipient and have communication from the federal agent to support that determination. However, current program personnel were unaware that the agreement between the Department and the entity identified the entity as a subrecipient because the determination was made by program personnel that did not have adequate experience with determination of subrecipients. Effect: The Department is not compliance with Federal Regulations. Repeat Finding: Yes Recommendation: We recommend the Department implement procedures to ensure compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. Additionally, we recommend the Department review the Federal Regulations to ensure the required elements are included in the subaward agreements. In general, the Department could benefit from improved processes over identification of entities at subrecipients or contractors and related tracking/monitoring of those entities identified as subrecipients.2022-002 (Previously 2021-001) Subrecipient Monitoring (Continued) Views of Responsible Officials: The Early Childhood Education and Care Department (ECECD) agrees with this audit finding and the Family Support and Early Intervention Division (FSEI) agrees with the recommendation that the Department could benefit from improved processes. To ensure this does not occur again, the FSEI Director and Deputy Director will implement procedures for program managers to ensure adequate compliance with required monitoring of its subrecipients, including review of financial reporting provided by its subrecipients. The FESI Director and Deputy Director will ensure that program staff are adequately trained on subrecipient monitoring. The FESI Director and Deputy Director will work with the Administrative Services Division (ASD) Director, Chief Financial Officer (CFO) and Grants Manager to verify subrecipient status and to ensure required elements are included in subaward agreements. Furthermore, the FSEI Director and Deputy Director will implement an internal review process to ensure program and financial monitoring is aligned and involves a third level of review by ASD Director, CFO and Grants Manager and other program personnel. The timeline is June 30, 2023.
Finding No.: 2022-004 Monitoring Procedures and Risk Assessment Process Federal Agency: Department of Health and Human Services (DHHS) Assistance Listing No.: 93.958 Requirement: Subrecipient Monitoring Type of Finding: Material Weakness Program: Block Grants for Community Mental Health Services Federal award no. and year: 1B09SM082596-01 10/01/19 ? 09/30/21 1B09SM083798-01 10/01/20 ? 09/30/22 1B09SM083952-01 03/15/21 ? 03/14/23 1B09SM085353-01 03/01/21 ? 09/30/25 1B09SM085881-01 09/01/21 ? 09/30/25 Criteria: In accordance with 2 CFR section 200.331, all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. In addition, all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: Although the program did not have any subrecipients that required a single audit report to be obtained during the fiscal year, we were informed by program personnel that the program was unable to fill vacant positions that would monitor this compliance requirement. As a result, the control over this compliance requirement was not in place during the current fiscal year. Context: The program had six subrecipients in FY2022, none of which expended more than $750,000 during the year. However, the program did not have any personnel monitoring subrecipient expenditures and reviewing single audit reports as applicable. Cause: According to management, the program did not have sufficient staff available who are qualified to conduct subrecipient monitoring. Effect: Failure to properly monitor subrecipients could lead to noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification as a Repeat Finding, if applicable: See finding 2021-005 included in the Summary Schedule of Prior Audit Findings. Recommendation: We recommend the Department hire adequate staff resources to follow its procedures and internal controls to ensure compliance with Federal requirements. Views of Responsible Officials and Planned Corrective Action: See Part VI Correction Action Plan.
Finding No.: 2022-004 Monitoring Procedures and Risk Assessment Process Federal Agency: Department of Health and Human Services (DHHS) Assistance Listing No.: 93.958 Requirement: Subrecipient Monitoring Type of Finding: Material Weakness Program: Block Grants for Community Mental Health Services Federal award no. and year: 1B09SM082596-01 10/01/19 ? 09/30/21 1B09SM083798-01 10/01/20 ? 09/30/22 1B09SM083952-01 03/15/21 ? 03/14/23 1B09SM085353-01 03/01/21 ? 09/30/25 1B09SM085881-01 09/01/21 ? 09/30/25 Criteria: In accordance with 2 CFR section 200.331, all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. In addition, all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: Although the program did not have any subrecipients that required a single audit report to be obtained during the fiscal year, we were informed by program personnel that the program was unable to fill vacant positions that would monitor this compliance requirement. As a result, the control over this compliance requirement was not in place during the current fiscal year. Context: The program had six subrecipients in FY2022, none of which expended more than $750,000 during the year. However, the program did not have any personnel monitoring subrecipient expenditures and reviewing single audit reports as applicable. Cause: According to management, the program did not have sufficient staff available who are qualified to conduct subrecipient monitoring. Effect: Failure to properly monitor subrecipients could lead to noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification as a Repeat Finding, if applicable: See finding 2021-005 included in the Summary Schedule of Prior Audit Findings. Recommendation: We recommend the Department hire adequate staff resources to follow its procedures and internal controls to ensure compliance with Federal requirements. Views of Responsible Officials and Planned Corrective Action: See Part VI Correction Action Plan.
Finding No.: 2022-009 Subrecipient Monitoring Federal Agency: Department of Health and Human Services (DHHS) Assistance Listing No.: 93.243 Requirement: Subrecipient Monitoring Type of Finding: Material Noncompliance and Material Weakness Program: Substance Abuse and Mental Health Services Federal award no. and year: 5H79SP081001-03 09/30/20 ? 09/29/21 5H79SP081001-04 09/30/21 ? 09/29/22 5H79TI026663-05 09/30/20 ? 09/29/21 5H79TI080196-04 09/30/20 ? 09/29/21 Criteria: In accordance with 2 CFR section 200.331, all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. In addition, all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: The program did not comply with its documented monitoring procedures consistently. Context: Of a total 19 contracts, we selected three contracts based on a non-statistical sample. We noted that for one of the three contracts selected, the required monitoring procedures were not performed based on the program?s documented procedures. Cause: There was a lack of diligence in following documented monitoring procedures. Effect: Failure to follow a subrecipient monitoring policy that meets the requirements in 2 CFR section 200.331 results in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification as a Repeat Finding, if applicable: Not applicable Recommendation: We recommend that management follow its documented monitoring procedures for all subrecipient contracts. Views of Responsible Officials and Planned Corrective Action: See Part VI Corrective Action Plan.
Department of Education, passed through the Minnesota Department of Education CFDA No. 84.027 and 84.173, award numbers 0397-52-000 FIN 419, 0397-52-000 FIN 420, 0397-52-000 FIN 140, 0397-52-000 FIN 425 Award year 2022 Special Education Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria ? Requirements contained in 2 CFR Part 200.331 specifies that pass-through entities be responsible for identifying Federal Award information and applicable compliance requirements at the time of awards to subrecipients; for monitoring the subrecipient?s use of Federal awards; providing reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; ensuring that subrecipients have required audits completed, reviewing the results of those audits; and evaluating the impact of subrecipient activities on the pass-through entity?s ability to comply with applicable Federal regulations. Condition ? The agreements between Lake Agassiz Education Cooperative and its subrecipients did not contain language set forth in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Cause ? Lake Agassiz Education Cooperative?s agreements with subrecipients must properly follow Uniform Guidance and no formal monitoring procedures were in place. Effect ? Lacking controls could lead to noncompliance with the requirements of the program by subrecipients and could require the return of grant funds to the grantor agency or the entity receiving less grant funds than they were eligible for. Questioned Costs ? None reported Context/Sampling ? Testing of 100% of the subrecipient entities were selected for subrecipient monitoring testing. Repeat Finding from Prior Year ? No, as a Uniform Guidance audit was not required in the previous two years. Recommendation ? We recommend Lake Agassiz Education Cooperative maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring processes over subrecipient entities. Views of Responsible Officials ? There is no disagreement with the audit finding.
Department of Education, passed through the Minnesota Department of Education CFDA No. 84.027 and 84.173, award numbers 0397-52-000 FIN 419, 0397-52-000 FIN 420, 0397-52-000 FIN 140, 0397-52-000 FIN 425 Award year 2022 Special Education Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria ? Requirements contained in 2 CFR Part 200.331 specifies that pass-through entities be responsible for identifying Federal Award information and applicable compliance requirements at the time of awards to subrecipients; for monitoring the subrecipient?s use of Federal awards; providing reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; ensuring that subrecipients have required audits completed, reviewing the results of those audits; and evaluating the impact of subrecipient activities on the pass-through entity?s ability to comply with applicable Federal regulations. Condition ? The agreements between Lake Agassiz Education Cooperative and its subrecipients did not contain language set forth in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Cause ? Lake Agassiz Education Cooperative?s agreements with subrecipients must properly follow Uniform Guidance and no formal monitoring procedures were in place. Effect ? Lacking controls could lead to noncompliance with the requirements of the program by subrecipients and could require the return of grant funds to the grantor agency or the entity receiving less grant funds than they were eligible for. Questioned Costs ? None reported Context/Sampling ? Testing of 100% of the subrecipient entities were selected for subrecipient monitoring testing. Repeat Finding from Prior Year ? No, as a Uniform Guidance audit was not required in the previous two years. Recommendation ? We recommend Lake Agassiz Education Cooperative maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring processes over subrecipient entities. Views of Responsible Officials ? There is no disagreement with the audit finding.
Department of Education, passed through the Minnesota Department of Education CFDA No. 84.027 and 84.173, award numbers 0397-52-000 FIN 419, 0397-52-000 FIN 420, 0397-52-000 FIN 140, 0397-52-000 FIN 425 Award year 2022 Special Education Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria ? Requirements contained in 2 CFR Part 200.331 specifies that pass-through entities be responsible for identifying Federal Award information and applicable compliance requirements at the time of awards to subrecipients; for monitoring the subrecipient?s use of Federal awards; providing reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; ensuring that subrecipients have required audits completed, reviewing the results of those audits; and evaluating the impact of subrecipient activities on the pass-through entity?s ability to comply with applicable Federal regulations. Condition ? The agreements between Lake Agassiz Education Cooperative and its subrecipients did not contain language set forth in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Cause ? Lake Agassiz Education Cooperative?s agreements with subrecipients must properly follow Uniform Guidance and no formal monitoring procedures were in place. Effect ? Lacking controls could lead to noncompliance with the requirements of the program by subrecipients and could require the return of grant funds to the grantor agency or the entity receiving less grant funds than they were eligible for. Questioned Costs ? None reported Context/Sampling ? Testing of 100% of the subrecipient entities were selected for subrecipient monitoring testing. Repeat Finding from Prior Year ? No, as a Uniform Guidance audit was not required in the previous two years. Recommendation ? We recommend Lake Agassiz Education Cooperative maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring processes over subrecipient entities. Views of Responsible Officials ? There is no disagreement with the audit finding.
Department of Education, passed through the Minnesota Department of Education CFDA No. 84.027 and 84.173, award numbers 0397-52-000 FIN 419, 0397-52-000 FIN 420, 0397-52-000 FIN 140, 0397-52-000 FIN 425 Award year 2022 Special Education Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria ? Requirements contained in 2 CFR Part 200.331 specifies that pass-through entities be responsible for identifying Federal Award information and applicable compliance requirements at the time of awards to subrecipients; for monitoring the subrecipient?s use of Federal awards; providing reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; ensuring that subrecipients have required audits completed, reviewing the results of those audits; and evaluating the impact of subrecipient activities on the pass-through entity?s ability to comply with applicable Federal regulations. Condition ? The agreements between Lake Agassiz Education Cooperative and its subrecipients did not contain language set forth in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Cause ? Lake Agassiz Education Cooperative?s agreements with subrecipients must properly follow Uniform Guidance and no formal monitoring procedures were in place. Effect ? Lacking controls could lead to noncompliance with the requirements of the program by subrecipients and could require the return of grant funds to the grantor agency or the entity receiving less grant funds than they were eligible for. Questioned Costs ? None reported Context/Sampling ? Testing of 100% of the subrecipient entities were selected for subrecipient monitoring testing. Repeat Finding from Prior Year ? No, as a Uniform Guidance audit was not required in the previous two years. Recommendation ? We recommend Lake Agassiz Education Cooperative maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring processes over subrecipient entities. Views of Responsible Officials ? There is no disagreement with the audit finding.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that pass-through entities clearly identify to each subrecipient significant Federal subaward information, including identifying award numbers, subaward period dates and budget dates, Federal Assistance Listings number and Title, and appropriate terms and conditions concerning closeout of the subaward. Typically this requirement is satisfied by utilizing a subrecipient contract, reflecting all necessary information, and requiring execution showing acknowledgement of the terms by both parties. 2 CFR section 200.332(b) requires that pass-through entities evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. The evaluation of this risk should include the subrecipient?s prior experience with the same or similar subawards, the results of previous subrecipient audits, whether the subrecipient has new personnel or substantially changed systems, and the extent and results of federal awarding agency monitoring if the subrecipient also receives federal awards directly. 2 CFR section 200.331(f) requires that pass-through entities verify that subrecipients expected to be audited are taking timely and appropriate action on deficiencies detected through audits. Condition: Internal controls should be in place to ensure the City is in compliance with all requirements of the federal award program. For the fiscal year ended June 30, 2022, the following conditions existed: ? A risk assessment, required by 2 CFR section 200.332(b), was not performed on the City?s subrecipient of grant funds. ? The City did not verify whether the subrecipient of the grant funds was required to be audited, as required by 2 CFR section 200.331(f). ? The agreement between the City and its subrecipient did not include a description of the program?s compliance requirements, as required by 2 CFR section 200.331(a), including the specific requirements for the subrecipient?s periodic reporting to the City. Context/Cause: The City did not have adequate internal controls to ensure compliance with subrecipient monitoring requirements. Testing was performed over each requirement for the City, who had a single subrecipient for the fiscal year ended June 30, 2022. Effect: Noncompliance at the subrecipient level may occur due to the subrecipient not being aware of all of the grant?s requirements. Without a risk assessment being performed on the City?s subrecipient for its grant funds, the City will not be aware of problems with staffing or information systems of the subrecipient. Additionally, the City will be unable to effectively monitor the subrecipient if the City is unaware of whether the subrecipient is required to be audited. Recommendation: We recommend the City enhances internal controls to ensure compliance with subrecipient monitoring requirements. Auditee?s Response: We concur with the finding. We will take the necessary steps to ensure that subrecipient agreements include a communication of the federal requirements and that the City performs a risk assessment on subrecipients of federal funding.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that pass-through entities clearly identify to each subrecipient significant Federal subaward information, including identifying award numbers, subaward period dates and budget dates, Federal Assistance Listings number and Title, and appropriate terms and conditions concerning closeout of the subaward. Typically this requirement is satisfied by utilizing a subrecipient contract, reflecting all necessary information, and requiring execution showing acknowledgement of the terms by both parties. 2 CFR section 200.332(b) requires that pass-through entities evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. The evaluation of this risk should include the subrecipient?s prior experience with the same or similar subawards, the results of previous subrecipient audits, whether the subrecipient has new personnel or substantially changed systems, and the extent and results of federal awarding agency monitoring if the subrecipient also receives federal awards directly. 2 CFR section 200.331(f) requires that pass-through entities verify that subrecipients expected to be audited are taking timely and appropriate action on deficiencies detected through audits. Condition: Internal controls should be in place to ensure the City is in compliance with all requirements of the federal award program. For the fiscal year ended June 30, 2022, the following conditions existed: ? A risk assessment, required by 2 CFR section 200.332(b), was not performed on the City?s subrecipient of grant funds. ? The City did not verify whether the subrecipient of the grant funds was required to be audited, as required by 2 CFR section 200.331(f). ? The agreement between the City and its subrecipient did not include a description of the program?s compliance requirements, as required by 2 CFR section 200.331(a), including the specific requirements for the subrecipient?s periodic reporting to the City. Context/Cause: The City did not have adequate internal controls to ensure compliance with subrecipient monitoring requirements. Testing was performed over each requirement for the City, who had a single subrecipient for the fiscal year ended June 30, 2022. Effect: Noncompliance at the subrecipient level may occur due to the subrecipient not being aware of all of the grant?s requirements. Without a risk assessment being performed on the City?s subrecipient for its grant funds, the City will not be aware of problems with staffing or information systems of the subrecipient. Additionally, the City will be unable to effectively monitor the subrecipient if the City is unaware of whether the subrecipient is required to be audited. Recommendation: We recommend the City enhances internal controls to ensure compliance with subrecipient monitoring requirements. Auditee?s Response: We concur with the finding. We will take the necessary steps to ensure that subrecipient agreements include a communication of the federal requirements and that the City performs a risk assessment on subrecipients of federal funding.
2022-043 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require pass-through entities to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact which federal compliance requirements recipients are subject to and how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). For recipients meeting the definition of a subrecipient, federal regulations require pass-through entities to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk to ensure subawards are used appropriately. We reviewed the department?s classification of a sample of eight of 40 Mental Health Block Grant (MHBG) and 11 of 76 Substance Abuse Block Grant (SABG) recipients of federal funds. We judgmentally selected an additional 11 MHBG and 30 SABG recipients for review after our review of the initial sample of recipients identified inconsistencies in the classification of recipients. Based on the following inconsistencies identified in our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and the related expenditures are reported accordingly. As a result, the SEFA may incorrectly report pass-through or direct expenditures. ? One recipient of MHBG funds and 13 recipients of SABG funds were classified as contractors by the department; however, other recipients providing the same services were classified as subrecipients. As they were identified as contractors, a SEFA correction of $1.4 million was made to report as direct expenditures rather than pass-through expenditures. ? Three recipients of MHBG funds and one recipient of SABG funds were classified as subrecipients by the department, but it was unclear if each met the definition of a subrecipient. ? One recipient of MHBG funds was classified as a contractor and appeared to meet the definition of a contractor; however, payments made to this recipient were recorded as pass-through expenditures. A SEFA correction of $329 thousand was made to report as direct expenditures rather than pass-through expenditures. ? One recipient of SABG funds was classified as neither contractor nor subrecipient. A SEFA correction of $215 thousand was made to report as direct expenditures rather than pass-through expenditures. We also inquired of the department?s risk assessment and monitoring activities for subrecipients. Based on our inquiries, the department does not have a formal implemented process for performing risk assessments to determine appropriate monitoring activities. Moreover, the department has not implemented a formal process to ensure subrecipients comply with federal regulations, terms and conditions of the subaward, and that subaward performance goals are achieved. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management ensure recipients of federal funds are appropriately identified as subrecipients or contractors and the corresponding disbursement of federal funds are appropriately reported as direct or pass-through expenditures. We further recommend department management comply with subrecipient monitoring requirements, develop and implement internal controls to ensure risk assessments are performed and documented for each subrecipient, and monitoring activities are completed and documented according to risk assessment results.
2022-043 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require pass-through entities to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact which federal compliance requirements recipients are subject to and how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). For recipients meeting the definition of a subrecipient, federal regulations require pass-through entities to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk to ensure subawards are used appropriately. We reviewed the department?s classification of a sample of eight of 40 Mental Health Block Grant (MHBG) and 11 of 76 Substance Abuse Block Grant (SABG) recipients of federal funds. We judgmentally selected an additional 11 MHBG and 30 SABG recipients for review after our review of the initial sample of recipients identified inconsistencies in the classification of recipients. Based on the following inconsistencies identified in our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and the related expenditures are reported accordingly. As a result, the SEFA may incorrectly report pass-through or direct expenditures. ? One recipient of MHBG funds and 13 recipients of SABG funds were classified as contractors by the department; however, other recipients providing the same services were classified as subrecipients. As they were identified as contractors, a SEFA correction of $1.4 million was made to report as direct expenditures rather than pass-through expenditures. ? Three recipients of MHBG funds and one recipient of SABG funds were classified as subrecipients by the department, but it was unclear if each met the definition of a subrecipient. ? One recipient of MHBG funds was classified as a contractor and appeared to meet the definition of a contractor; however, payments made to this recipient were recorded as pass-through expenditures. A SEFA correction of $329 thousand was made to report as direct expenditures rather than pass-through expenditures. ? One recipient of SABG funds was classified as neither contractor nor subrecipient. A SEFA correction of $215 thousand was made to report as direct expenditures rather than pass-through expenditures. We also inquired of the department?s risk assessment and monitoring activities for subrecipients. Based on our inquiries, the department does not have a formal implemented process for performing risk assessments to determine appropriate monitoring activities. Moreover, the department has not implemented a formal process to ensure subrecipients comply with federal regulations, terms and conditions of the subaward, and that subaward performance goals are achieved. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management ensure recipients of federal funds are appropriately identified as subrecipients or contractors and the corresponding disbursement of federal funds are appropriately reported as direct or pass-through expenditures. We further recommend department management comply with subrecipient monitoring requirements, develop and implement internal controls to ensure risk assessments are performed and documented for each subrecipient, and monitoring activities are completed and documented according to risk assessment results.
2022-043 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require pass-through entities to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact which federal compliance requirements recipients are subject to and how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). For recipients meeting the definition of a subrecipient, federal regulations require pass-through entities to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk to ensure subawards are used appropriately. We reviewed the department?s classification of a sample of eight of 40 Mental Health Block Grant (MHBG) and 11 of 76 Substance Abuse Block Grant (SABG) recipients of federal funds. We judgmentally selected an additional 11 MHBG and 30 SABG recipients for review after our review of the initial sample of recipients identified inconsistencies in the classification of recipients. Based on the following inconsistencies identified in our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and the related expenditures are reported accordingly. As a result, the SEFA may incorrectly report pass-through or direct expenditures. ? One recipient of MHBG funds and 13 recipients of SABG funds were classified as contractors by the department; however, other recipients providing the same services were classified as subrecipients. As they were identified as contractors, a SEFA correction of $1.4 million was made to report as direct expenditures rather than pass-through expenditures. ? Three recipients of MHBG funds and one recipient of SABG funds were classified as subrecipients by the department, but it was unclear if each met the definition of a subrecipient. ? One recipient of MHBG funds was classified as a contractor and appeared to meet the definition of a contractor; however, payments made to this recipient were recorded as pass-through expenditures. A SEFA correction of $329 thousand was made to report as direct expenditures rather than pass-through expenditures. ? One recipient of SABG funds was classified as neither contractor nor subrecipient. A SEFA correction of $215 thousand was made to report as direct expenditures rather than pass-through expenditures. We also inquired of the department?s risk assessment and monitoring activities for subrecipients. Based on our inquiries, the department does not have a formal implemented process for performing risk assessments to determine appropriate monitoring activities. Moreover, the department has not implemented a formal process to ensure subrecipients comply with federal regulations, terms and conditions of the subaward, and that subaward performance goals are achieved. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management ensure recipients of federal funds are appropriately identified as subrecipients or contractors and the corresponding disbursement of federal funds are appropriately reported as direct or pass-through expenditures. We further recommend department management comply with subrecipient monitoring requirements, develop and implement internal controls to ensure risk assessments are performed and documented for each subrecipient, and monitoring activities are completed and documented according to risk assessment results.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Criteria: 2 CFR 200.331 states that all pass-through entities must ensure that every sub-award is
Criteria: 2 CFR 200.331 states that all pass-through entities must ensure that every sub-award is
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.