2 CFR 200 § 200.331

Findings Citing § 200.331

Subrecipient and contractor determinations.

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2,576
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About this section
Section 200.331 outlines how entities receiving Federal funds can be classified as either subrecipients or contractors, depending on their role in managing the funds. Pass-through entities must assess each relationship individually, focusing on the nature of the work rather than the agreement's form, affecting how Federal assistance is distributed and monitored.
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FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of North Dakota
Compliance Requirement: M
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as require...

CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.

FY End: 2024-06-30
State of New Hampshire
Compliance Requirement: I
Finding Reference: 2024-011 NH Governor’s Office of Emergency Relief and Recovery COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Procurement Type of Finding: Significant Deficiency Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria An entity may concurre...

Finding Reference: 2024-011 NH Governor’s Office of Emergency Relief and Recovery COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Procurement Type of Finding: Significant Deficiency Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria An entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor. The pass-through entity is responsible for making case-by-case determinations to determine whether the entity receiving Federal funds is a subrecipient or a contractor. The Federal agency may require the pass-through entity to comply with additional guidance to make these determinations, provided such guidance does not conflict with this section. The Federal agency does not have a direct legal relationship with subrecipients or contractors of any tier; however, the Federal agency is responsible for monitoring the pass-through entity's oversight of first-tier subrecipients. All of the characteristics listed below may not be present in all cases, and some characteristics from both categories may be present at the same time. No single factor or any combination of factors is necessarily determinative. The pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. In making this determination, the substance of the relationship is more important than the form of the agreement (2 CFR 200.331) Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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 As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities and third-party contracts to support allowable activities under the federal program. As part of our testwork over the completeness of the procurement (contracts) and subrecipient grants populations, we identified the following: A. For 91 procurement samples selected for testwork, 12 sample selections did not appear to be contracts. 11 of 12 sample items appeared to be a beneficiary payment. The remaining 1 sample items appeared to be a subrecipient grant agreements. B. For 2 of 24 subrecipient grant samples selected for testwork, 2 sample selections did not appear to be a subrecipient grant. 1 of the 2 sample selections appeared to be a contract and the other 1 was a forgivable loan payment that appeared to be a beneficiary payment. No procurement noncompliance was identified for the contract and subrecipient samples subject to testwork. Cause The cause of the condition found is primarily due to insufficient controls related to the determination of vendor versus subrecipient versus beneficiary payment in order to determine what additional monitoring procedures the State needs to be perform and to determine if the recipient needs to comply with federal compliance requirements. . Effect The effect of the condition found is that the State may not have properly classified contracts, beneficiary and subrecipient awards. Questioned Costs: None. Recommendation We recommend that the State continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State. View of Responsible Officials: Management concurs with the finding above.

FY End: 2024-06-30
State of Hawaii Department of Health
Compliance Requirement: M
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 condi...

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. To ensure compliance with the Federal requirements, the program has documented monitoring policies and procedures. Condition: The program did not comply with its documented monitoring procedures, which includes performing on-site visits, desk reviews and/or conducting monthly progress meetings and obtaining and reviewing single audit reports for subrecipients that expend more than $750,000 of Federal funds. Context: Of a total 10 subrecipient 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. Of the 10 subrecipient contracts, the program was required to obtain and review a single audit report for one subrecipient that expended more than $750,000 during the year. We noted that the program did not obtain and review a single audit report for the subrecipient. Cause: Based on further inquiry with Department personnel, we noted that there was a lack of diligence in following the 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 program management follow its documented monitoring procedures for all subrecipient contracts. Views of Responsible Officials: Client agrees with finding, and the unabridged version of their response can be found in the Corrective Action Plan issued by the Department.

FY End: 2024-06-30
State of Hawaii Department of Health
Compliance Requirement: G
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 condi...

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. To ensure compliance with the Federal requirements, the program has documented monitoring policies and procedures. Condition: The program did not comply with its documented monitoring procedures, which includes performing on-site visits, desk reviews and/or conducting monthly progress meetings and obtaining and reviewing single audit reports for subrecipients that expend more than $750,000 of Federal funds. Context: Of a total 10 subrecipient 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. Of the 10 subrecipient contracts, the program was required to obtain and review a single audit report for one subrecipient that expended more than $750,000 during the year. We noted that the program did not obtain and review a single audit report for the subrecipient. Cause: Based on further inquiry with Department personnel, we noted that there was a lack of diligence in following the 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 program management follow its documented monitoring procedures for all subrecipient contracts. Views of Responsible Officials: Client agrees with finding, and the unabridged version of their response can be found in the Corrective Action Plan issued by the Department.

FY End: 2024-06-30
County of Solano
Compliance Requirement: M
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the...

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

FY End: 2024-06-30
County of Solano
Compliance Requirement: M
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the...

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
State of Oregon
Compliance Requirement: M
2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Su...

2024-009 Oregon Health Authority Continue to implement and strengthen 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 93.958 Block Grants for Community Mental Health Services (COVID-19) 93.959 Block Grants for Prevention and Treatment of Substance Abuse 93.959 Block Grants for Prevention and Treatment of Substance Abuse (COVID-19) Federal Award Numbers and Years: 93.958: B09SM086032, 2022; B09SM087383, 2023; B09SM085378, 2022 (COVID-19) 93.959: B08TI084667, 2022; B08TI085829, 2023; B08TI083963, 2022 (COVID-19) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Findings: 2023-020; 2022-043 Questioned Costs: N/ACriteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require passthrough 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 recipient contracts with expenditures recorded during state fiscal year 2024. The sample included 7 of 34 Block Grants for Community Mental Health (MHBG) and 13 of 76 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (SUPTRS). Based on the following inconsistencies identified during our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and whether the related expenditures are reported accordingly. • One recipient of SUPTRS funds was classified as a subrecipient by the department, but it was unclear if it met the definition of a subrecipient. • Two recipients of MHBG funds and 2 recipients of SUPTRS funds were classified as contractors; however, payments made to these recipients were recorded as passthrough expenditures. In each case, the recipient appeared to meet the definition of a subrecipient. In addition, we followed up on similar errors noted during the prior fiscal year. Six recipients of MHBG funds and 1 recipient of SUPTRS funds appeared to be inappropriately categorized as subrecipients in the prior fiscal year yet reported passthrough expenditures in state fiscal year 2024. Finally, post-award monitoring was not completed for 5 of 7 MHBG and 8 of 13 SUPTRS subrecipients selected for testing. The above issues did not result in questioned costs. However, a total of $3,875,104 in MHBG funds and $357,406 in SUPTRS funds may be inappropriately reported as passthrough expenditures instead of direct expenditures. We inquired about the department’s risk assessment and monitoring activities for subrecipients. During state fiscal year 2024, the department began to develop and implement new processes and controls to help staff better distinguish recipients as subrecipients or contractors and ensure compliance with federal subrecipient monitoring requirements. Specifically, the department developed a determination checklist using the subrecipient determination criteria in 2 CFR 200.331. Staff are to complete the determination checklist for each new contract. Identified subrecipients are then required to complete a self-risk assessment tool, the result of which generates a monitoring plan outlining what monitoring procedures department staff will perform. In addition, the department is working with another entity to develop subrecipient monitoring training videos. Implementation of the above processes and controls was initiated near the end of state fiscal year 2024 with full implementation planned the end of state fiscal year 2025. We recommend department management continue to implement and strengthen controls to 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 passthrough expenditures. We further recommend department management comply with subrecipient monitoring requirements, continue to 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 the risk assessment results.

FY End: 2024-06-30
The Astraea Foundation, Inc.
Compliance Requirement: M
Finding 2024-003: Subrecipient Management and Monitoring (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: As stated in 2 CFR 200.331 part (b), 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 procedures to prescribe to each individual subrecipient. Additionally, per ...

Finding 2024-003: Subrecipient Management and Monitoring (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: As stated in 2 CFR 200.331 part (b), 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 procedures to prescribe to each individual subrecipient. Additionally, per 2 CFR 200.332(a), pass-through entities must include specific information in subrecipient agreements, such as the Assistance Listing Number (ALN), compliance requirements, and monitoring responsibilities, to ensure proper oversight and accountability. Condition: Astraea has a subaward policy, which requires a risk assessment form be completed for each potential subrecipient. However, this step was not completed for all of the subrecipients in which Astraea engaged with during the fiscal year. Furthermore, during our review of subrecipient agreements, we noted that certain agreements did not contain all the required elements as outlined in 2 CFR 200.332(a). Cause: Astraea did not adhere to its policy in regards to risk assessment procedures. Additionally, Astraea did not have formalized procedures for ensuring all required elements, including the ALN, were included in subrecipient agreements. Context: Astraea failed to perform risk assessment procedures. Our audit work in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Additionally, during our review of subrecipient agreements we noted two that did not include the required ALN, which is necessary to properly identify the source of Federal funding. Effect: Astraea could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Additionally, the absence of required information in subrecipient agreements increases the risk of noncompliance with Federal grant requirements and improper use of Federal funds.Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2023-004 Recommendation: We recommend Astraea adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, Astraea should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels. We also recommend Astraea require its subrecipients to submit financial reports demonstrating use of each advance before advancing more funds, to ensure subrecipients are expending funds appropriately. Furthermore, Astraea should implement enhanced review procedures to ensure all subrecipient agreements include the required information before execution, such as, updating standard agreement templates.

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