Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Condition: For 1 out of 3 selections, management was unable to provide evidence that the Single Audit Report was reviewed. For 3 out of 3 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 3 out of 3 selections, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Federal Agency: Department of the Treasury (Treasury) Federal Program: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds SLFRP4542 State Agency: Office of Administration (OA) Type of Finding: A - Internal Control (Material Weakness) and Material Noncompliance B - Internal Control (Material Weakness) and Material Noncompliance Compliance Requirement: Subrecipient Monitoring As noted in our previous audit, the OA has not established policies and procedures regarding monitoring subrecipients of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. As a result, the OA did not comply with the Uniform Guidance (UG) requirements regarding identifying and monitoring subrecipients of the SLFRF program. The OA is the lead agency responsible for administering the SLFRF program. The purpose of the SLFRF program is to provide funding to respond to the COVID-19 public health emergency (PHE) or its negative impacts; respond to workers performing essential work during the PHE; provide government services, to the extent of the reduction in revenue due to the PHE (revenue replacement); make necessary investments in water, sewer, or broadband infrastructure; provide emergency relief from natural disasters or the negative economic impacts of natural disasters; and finance certain surface transportation and housing projects. The OA and various state agencies designed projects within the various allowable SLFRF program categories, and are responsible for administering the projects. The OA developed the American Rescue Plan Act Grant Management Portal (portal) to serve as the official repository of information and documentation supporting each SLFRF program project. The state agencies upload supporting documentation to the portal, including contracts, payment requests, and other supporting documentation. Most payments are made on a reimbursement basis. The OA reviews each payment request and processes the payments. Some SLFRF program projects are administered through subawards. The OA establishes contracts with each subrecipient that outline various SLFRF program requirements, terms, and conditions. In the Schedule of Expenditures of Federal Awards (SEFA), the OA reported approximately $186 million was passed through to subrecipients of the SLFRF program during the year ended June 30, 2024. This amount represents approximately 30 percent of the SLFRF program expenditures. These awards were administered through the OA and 7 other state agencies. However, as noted in finding point A., the amounts are not accurate due to subrecipient determination errors. In response to our prior audit finding, the OA held a training for state agency personnel in August 2024 and sent a letter to state agencies in January 2025 (after the current audit period), covering agency responsibilities related to certain SLFRF program subrecipient monitoring requirements, such as subrecipient determinations and single audits. Of the 7 state agencies that administered subawards reported in the SEFA during the year ended June 30, 2024, 4 administered the majority of the subawards, with payments totaling approximately $181 million, or 97 percent of the total subrecipient payments reported in the SEFA. These 4 state agencies were the Department of Mental Health (DMH), Department of Higher Education and Workforce Development (DHEWD), Department of Natural Resources (DNR), and the Department of Economic Development (DED). Our review and testing of subrecipient monitoring procedures focused on the OA and the 4 state agencies. For the 4 state agencies, a total of 212 recipients were identified as subrecipients in the SEFA. However, as noted in finding point A., this count is not accurate due to subrecipient determination errors. To understand the OA and state agency procedures, and to test compliance with subrecipient monitoring requirements, we randomly selected a sample of payments to 21 subrecipients for the 4 state agencies. In addition, we judgmentally selected an additional subrecipient at one of the agencies because we had received citizen concerns regarding the administration of the subrecipient project. The 22 subrecipients were awarded a total of approximately $230 million in SLFRF program funding and were paid a total of approximately $77.9 million during the year ended June 30, 2024. We reviewed records in the portal supporting the subawards and 1 payment for each of the 22 subrecipients. We reviewed payments totaling approximately $5.9 million. For the judgmentally-selected subrecipient, we reviewed documentation of the state agency's monitoring of the subrecipient, including documentation of decisions to terminate (June 2024), not reinstate (December 2024), and reinstate (June 2025) the project. No significant issues were identified in this review. A. Subrecipient Determination The OA has not established policies and procedures to determine whether recipients of the SLFRF program funds are subrecipients or contractors. As a result, some recipients were incorrectly classified, and the OA lacks a complete and accurate listing of subrecipients. Subrecipient monitoring requirements are outlined in the UG. Regulation 2 CFR Section 200.331 states a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. The classification of a subrecipient is dependent on whether the entity is responsible for making eligibility determinations for assistance, has its performance measured in relation to whether the objectives of the federal program were met, has responsibility for programmatic decision-making, is responsible for adherence to federal program requirements, and uses the federal funds to carry out a program for its public purpose. The OA did not evaluate each SLFRF program recipient for the UG criteria, and did not make a determination of whether the entity was a subrecipient or contractor. OA officials assigned responsibility for making these determinations and identifying subrecipients to the applicable state agencies, but did not provide clear guidance to the state agencies or ensure the state agencies properly performed and documented the determinations. One of the 4 state agencies had not documented their determinations for any of their sampled subrecipients and another state agency had not documented its determinations for 2 of 4 sampled subrecipients. Our analysis and review of the population of 212 subrecipients identified in the SEFA for the 4 state agencies revealed 1 state agency incorrectly recorded 2 contractors (office supply and electrical supply companies), with payments totaling $6,509, as subrecipients. The OA is the lead agency responsible for administering the SLFRF program. Without adequate procedures over subrecipient or contractor determinations, the OA lacks assurance that its subrecipients have been identified for subrecipient monitoring purposes. The OA Corrective Action Plan and Summary Schedule of Prior Audit Findings for prior audit finding number 2023-010 state the OA disagrees that it needs to develop policies and procedures regarding subrecipient determinations since the requirements are already stated in the Uniform Guidance and SLFRF program regulations. However, documented policies and procedures are necessary to clearly communicate responsibilities to the state agencies, prevent misunderstandings, and demonstrate adequate internal controls over compliance with subrecipient monitoring requirements. Regulation 2 CFR Section 200.303(a) requires the non-federal entity to "[e]stablish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission." Paragraph 3.10 of the Standards for Internal Control in the Federal Government, also known as the Green Book, states, "[e]ffective documentation assists in management's design of internal control by establishing and communicating the who, what, when, where, and why of internal control execution to personnel. Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel, as well as a means to communicate that knowledge as needed to external parties, such as external auditors." Paragraph 12.01 states, "[m]anagement should implement control activities through policies." B. Subrecipient Monitoring The OA did not implement an effective subrecipient monitoring program to monitor the SLFRF subrecipients. As a result, some subrecipient monitoring procedures were not performed as required by the UG. Regulation 2 CFR Section 200.332(b) states that pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Risk assessments may consider factors such as the subrecipient's prior experience with the same or similar subawards, the results of previous audits, whether the subrecipient has new personnel or new or substantially-changed systems, and the extent and results of federal awarding agency monitoring. Regulation 2 CFR Section 200.332(d) requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure the subrecipient is in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity; (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward; and (3) issuing a management decision for applicable findings pertaining only to the federal award provided to the subrecipient from the pass-through entity. Regulation 2 CFR Section 200.332(f) requires pass-through entities to verify that every subrecipient had a single audit when it is expected that the subrecipient spent $750,000 or more during the subrecipient's fiscal year. To monitor subrecipients of the SLFRF program, the OA relies on its pre-payment monitoring process. The OA does not perform any post-payment monitoring procedures, and relies on the state agencies to perform these procedures. The OA did not establish policies and procedures over the pre-payment review process and these reviews were not always clearly documented. In addition, the OA did not sufficiently communicate with the state agencies regarding subrecipient monitoring responsibilities or ensure the state agencies performed monitoring reviews. The information communicated to the state agencies in memos, emails, and periodic meetings and trainings with state agency personnel were not formalized in a policy and did not cover all relevant compliance requirements. In addition, the OA did not ensure risk assessments were performed or that subrecipients received single audits as required by the UG. Risk assessments The OA did not ensure required risk assessments for subrecipients of the SLFRF program were performed to determine the nature, timing, and extent of monitoring procedures necessary. Two of the 4 state agencies did not perform any risk assessments for the sampled subrecipients. OA officials indicated risk assessment procedures are the responsibility of the state agencies; however, the OA did not provide clear guidance to the state agencies or ensure the state agencies performed and used risk assessments as required. In addition to complying with federal requirements, risk assessments are necessary to ensure monitoring reviews are conducted with adequate frequency to help ensure subrecipient compliance with program requirements. OA pre-payment monitoring procedures The OA has not developed policies and procedures outlining its pre-payment monitoring procedures and did not always clearly document monitoring performed prior to making payments. In their review and approval of each SLFRF subrecipient payment request, OA officials stated they thoroughly review supporting documentation uploaded to the portal by the state agencies, including contracts, bid documentation, invoices, and other supporting documentation. OA officials further stated they review for compliance with certain types of SLFRF program compliance requirements, including allowable activities and allowable costs, procurement, and period of performance. However, the OA does not clearly document review procedures performed. For each of the 22 subrecipients sampled, the portal included documentation pertaining to some, but not all of the applicable compliance requirements. For example, for 5 subrecipient payments reviewed (for 2 state agencies), the portal included summary invoices, but did not include sufficiently detailed documentation showing compliance with the allowable activities and allowable costs and period of performance compliance requirements. Without documented policies and procedures and documentation of prepayment monitoring procedures performed, the OA cannot demonstrate subrecipient monitoring procedures were performed. Additional monitoring procedures The OA does not monitor subrecipients beyond the pre-payment monitoring process previously described. OA officials stated post-payment monitoring procedures are the responsibility of the state agencies; however, the OA did not sufficiently communicate with the agencies regarding subrecipient monitoring responsibilities or ensure the agencies performed monitoring reviews. Our review of subrecipient monitoring procedures at the 4 state agencies noted 3 agencies had developed written policies or procedures regarding subrecipient monitoring. We also noted state agency review procedures varied significantly, did not cover all significant compliance requirements, and were not always documented. While officials of some state agencies indicated they perform detailed pre-payment reviews for compliance with allowable activities and allowable costs, period of performance, and/or local match requirements, officials of some agencies explained they and the OA sometimes review only summary invoices of expenditures from the subrecipients prior to payment. Additionally, officials of all state agencies described various post-payment review procedures such as reviews for compliance with certain requirements, reviews of documentation supporting expenditures of funds advanced to the subrecipient, billing reviews of documentation supporting summary invoices, and/or reviews of the final work product; however, none of the agencies performed all of these procedures. In addition, the agencies could not always provide documentation such reviews had been performed for the sampled items. In addition to noncompliance with subrecipient monitoring requirements, the failure to ensure sufficient monitoring procedures were performed and documented increases the risk that subrecipient noncompliance will not be prevented or detected timely. Subrecipient audits The OA did not ensure the required reviews of single audit reports for applicable SLFRF program subrecipients were conducted. OA officials indicated the state agencies are responsible for ensuring subrecipients had a single audit, and reviewing and following up on the audit reports; however, the OA did not ensure the state agencies performed these procedures. All 4 agencies described procedures to monitor and follow up on single audit reports. Each subrecipient that spent in excess of $750,000 in federal awards during its fiscal year must obtain a single audit in accordance with the UG within 9 months after the end of the fiscal year. In addition to noncompliance with subrecipient monitoring requirements, the failure to ensure subrecipients received required audits and to review and follow up on the related audit reports, increases the risk that subrecipient noncompliance will not be identified and addressed. Conclusions The following table summarizes the results of our sampling at the 4 state agencies, presented in finding points A. and B. Instances in which a criterion was partially met are shown as the applicable number of items sampled. The OA is the lead agency responsible for administering the SLFRF program. OA officials indicated the state agencies were responsible for some of the subrecipient monitoring requirements. However, without clear communication and monitoring of these responsibilities, the OA lacks assurance of compliance with all subrecipient monitoring requirements. Without an established subrecipient monitoring program, the OA cannot provide assurance subrecipients are complying with SLFRF program requirements and there is increased risk that noncompliance with program requirements or subaward terms and conditions will go undetected, or that subaward performance goals will not be achieved. In addition, a subrecipient monitoring program is necessary to demonstrate adequate internal controls over compliance with subrecipient monitoring requirements. Regulation 2 CFR Section 200.303(a) requires the non-federal entity to "[e]stablish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing that Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission." Paragraph 3.10 of the Standards for Internal Control in the Federal Government, also known as the Green Book, states, "[e]ffective documentation assists in management's design of internal control by establishing and communicating the who, what, when, where, and why of internal control execution to personnel. Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel, as well as a means to communicate that knowledge as needed to external parties, such as external auditors." Paragraph 12.01 states, "[m]anagement should implement control activities through policies." Recommendations The OA: A. Develop policies and procedures to determine whether recipients of SLFRF program funds are subrecipients or contractors. Continue to work with the state agencies to ensure accurate and documented determinations are prepared for all recipients, and modify subrecipient records as needed. B. Develop a subrecipient monitoring program in accordance with the Uniform Guidance that includes performing risk assessments for each subrecipient for the purposes of determining the appropriate subrecipient monitoring procedures; monitoring for compliance with federal requirements and subaward terms and conditions, and ensuring subaward performance goals are achieved; and reviewing subrecipient single audit reports. Ensure tasks delegated to state agencies are adequately communicated and establish procedures to ensure those tasks are appropriately completed. Auditee's Response A. We partially agree with the auditor's finding. Our Corrective Action Plan includes an explanation and specific reasons for our disagreement and any planned actions to address the finding. B. We agree with the auditor's finding. Our Corrective Action Plan includes our planned actions to address the finding. Auditor's Comment The OA Corrective Action Plan states the OA partially agrees with Finding point A. because the OA completed training for all agencies regarding agency subrecipient monitoring responsibilities and distributed a memo instructing the agencies to develop subrecipient monitoring policies and procedures. However, as noted in the audit finding, the training was held and letter was sent to state agencies after the current audit period. Because the OA took no corrective action prior to or during the audit period, the internal control weaknesses and noncompliance occurred again in the current audit period.
2024-004: Subrecipient Determination and Monitoring Assistance Listing Number (ALN) and Title: 20.205 Highway Planning and Construction Federal Grantor: U.S. Department of Transportation (DOT) Passed-through: Oregon Department of Transportation (ODOT) Award Identification Numbers and Years: Finding is applicable to all 20.205 awards on the SEFA for 2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Noncompliance and Material Weakness in Internal Control over Compliance. Prior Year Audit Finding: No Criteria: 2 CFR 200.331 requires pass-through entities (PTEs) like LCOG to make case-by-case determinations whether an agreement casts the party receiving funds as a subrecipient or a contractor (vendor). This determination affects reporting on the SEFA (§200.510(b)(4)). Furthermore, 2 CFR 200.332 requires PTEs to evaluate each subrecipient's risk of noncompliance, monitor their activities to ensure compliance with federal requirements (including reviewing financial and performance reports), and verify that subrecipients subject to the Single Audit requirements have obtained the required audit and take appropriate action on any findings effecting the pass-through program (§200.332(b), (d), and (f)). Effective internal controls should ensure proper classification and that required monitoring activities are performed and documented. Condition: LCOG exhibited weaknesses in its process for determining and monitoring subrecipients under ALN 20.205. Specifically: LCOG did not correctly classify entities receiving funds. Multiple vendors were incorrectly identified as subrecipients on the draft SEFA provided for audit. Two entities meeting the definition of subrecipients were identified during audit procedures; however, LCOG had classified them as vendors and omitted them from the draft SEFA. As a result of misclassifying the actual subrecipients as vendors, LCOG did not perform required subrecipient monitoring activities for these entities, such as conducting and documenting a risk assessment or obtaining and reviewing their Single Audit reporting packages. Questioned Costs: None. Context: The misclassifications were identified during audit testing and review of the draft SEFA. While the entities omitted from the SEFA were later confirmed to be subrecipients, LCOG had not performed the required monitoring steps during the fiscal year. Subsequent review of the Single Audit reports for these two subrecipients during the audit process confirmed they had correctly reported the funds received from LCOG and disclosed no audit findings related to this program. No errors were noted in the initial contracting process with these entities. However, the lack of contemporaneous monitoring represents noncompliance and a control weakness. Cause: LCOG lacks adequate procedures for performing and documenting the subrecipient vs. contractor determination based on the criteria in 2 CFR 200.331. This initial failure led to inaccurate SEFA reporting and the subsequent failure to implement required monitoring protocols for entities that were, in fact, subrecipients. Effect: The failure to correctly identify and monitor subrecipients constitutes noncompliance with 2 CFR 200.332 and resulted in inaccurate SEFA reporting. Although no subrecipient noncompliance impacting the program was ultimately identified in this instance, the absence of required monitoring activities (including risk assessment and review of audit reports) creates a risk that subrecipient noncompliance could occur and not be detected by LCOG in a timely manner. This condition represents a material weakness in internal control over compliance. Recommendation: We recommend LCOG implement procedures to: 99 Formally document the determination of whether entities receiving federal funds are subrecipients or contractors prior to entering into agreements and preparing the SEFA, using the criteria in 2 CFR 200.331. Develop and implement a risk-based monitoring plan for all identified subrecipients, ensuring that required monitoring activities (including review of reports and Single Audits, where applicable) are performed and documented throughout the period of performance. Ensure the SEFA accurately reflects subrecipient relationships and amounts passed through. Auditee Views: While we agree that we did not have a formal monitoring plan in place, now that we are aware of the need for such a plan, we will put a plan in place immediately. Once we became aware, we immediately reviewed the single audit reports all subrecipients. As to whether all subrecipients were properly reported on the SEFA, LCOG and ODOT had been in discussions for several months over whether certain entities contracted by LCOG under the Secure Routes to Schools program were, in fact, subrecipients and was unclear due to conflicting guidance received from various individuals. We will begin consulting with ODOT prior to the audit to make sure they agree with the classification of fund recipients as either contractor or subrecipient.
2024-011 U.S. Department of Housing and Urban Development, For the period July 1, 2023, through June 30, 2024, ALN # 14.239– HOME Investment Partnerships Program Criteria: Per 2 CFR §200.331(b), 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. Furthermore, 2 CFR §200.332(d) requires pass-through entities to follow up on any audit findings identified in subrecipients’ Single Audit reports that pertain to the federal award. Condition: The City did not perform a documented risk assessment of subrecipients under the HOME program to determine the appropriate level and type of monitoring. Additionally, the City did not obtain or review subrecipients’ Single Audit reports to identify and follow up on any findings related to the HOME program. Two of the four contracts with expenditures in fiscal year 2024 were tested. Cause: The City has not established formal procedures to assess subrecipient risk or to review and follow up on audit findings related to the HOME program. Effect: Without a documented risk assessment and review of subrecipient audit reports: • The City may not tailor its monitoring procedures appropriately, increasing the risk of undetected noncompliance. • Potential issues identified in subrecipient audits may go unaddressed, jeopardizing the integrity of the program and federal funding. Recommendation: The City should implement formal procedures to conduct and document risk assessments for all subrecipients of the HOME program, obtain and review subrecipient Single Audit reports annually, follow up on any findings related to the HOME program to ensure corrective actions are taken. Questioned Costs: none
Finding 2024-002: Subrecipient Risk Assessment and Monitoring Federal Program: 19.345 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 sub-award for purposes of determining the appropriate sub-recipient monitoring procedures to prescribe to each individual sub-recipient (i.e. pre-award risk assessment procedures). Condition: We noted certain subrecipients did not have current risk assessments on file. The subrecipients were long standing partners of Invisible Children. In addition, Invisible Children did not have a procedure in place to document whether the subrecipients were subject to audit under Uniform Guidance each year (based on the threshold of U.S. Federal funding incurred). Cause: Invisible Children has conducted risk assessments when originally engaging with the subrecipients, but were not reviewing and updating the assessments on a routine basis, or when new agreements were signed. This was not required by their policy. Effect: The Organization could inadvertently engage in relationships with sub-recipients of higher risk without the appropriate level of oversight (monitoring) to ensure that subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted Context: Under the Uniform Guidance (2 CFR Part 200), Federal awarding agencies and passthrough entities are required to evaluate the risk of subrecipients and ensure compliance with audit requirements. Specifically, subrecipients that expend $750,000 or more in Federal awards during a fiscal year are subject to a Single Audit or program-specific audit. Pass-through entities must have documented procedures to annually assess which subrecipients meet this threshold and ensure that appropriate risk assessments and audit follow-ups are completed. In this case, Invisible Children has longstanding relationships with its subrecipients but lacks a formal procedure to document annual risk assessments and to verify whether subrecipients meet the audit threshold, which creates a risk of noncompliance with Federal requirements. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that the Organization update their policies to ensure that they comply with Uniform Guidance requirements regarding pre-award risk assessments as well as document annually whether the subrecipient was required to obtain an audit in accordance with the standards. If applicable, the Organization is to verify that the subrecipient is audited and review the results of the audit with respect to its funding.
Assistance Listing 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Program Condition: The city’s Department of Public Health (DPH) did not perform risk assessments or monitor the performance of three subrecipient entities tested for this program. Specifically, DPH did not evaluate the risk of fraud and non-compliance or review the financial and performance reports for these three entities. Funding for this program is received from the U.S. Department of Health and Human Services. Criteria: OMB’s Uniform Guidance 2 CFR Part 200.331(a) states that a subaward recipient may be considered a subrecipient of the pass-through agency if the recipient 1) determines who is eligible to receive federal assistance, 2) has its performance measured in relation to whether the objectives of a federal program were met, and 3) has responsibility for programmatic decision-making. OMB’s Uniform Guidance 2 CFR Part 200.332(c) states that the pass-through entity is responsible for evaluating each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. 2 CFR Part 200.332(f) further states that depending on the pass-through entity’s assessment of the risk posed by the subrecipient, the pass-through entity may need to provide training and technical assistance on program matters, perform site visits to review program operations, or arrange for other agreed-upon procedures, to ensure compliance with program requirements and achievement of performance goals. Finally, 2 CFR Part 200.332(e) requires the pass-through entity to monitor the activities of subrecipients by reviewing the financial and performance reports of subrecipients to ensure that the entities comply with federal statutes, regulations, and the terms and conditions of their subawards. Effect: Failure to perform risk assessments and review financial and performance reports for subrecipients resulted in noncompliance with subrecipient monitoring requirements set forth in the Uniform Guidance. Without these reviews, DPH may not adequately determine the appropriate level of monitoring needed to ensure that subrecipients comply with program requirements, federal regulations, and other requirements of their subawards. This noncompliance could also lead to the city having to pay back federal awards. Cause: DPH management misclassified these three entities as contractors, rather than subrecipients. For purposes of the Epidemiology and Laboratory Capacity Program, contracts between DPH and the three entities in question specifically state that each of the entities would serve as subrecipients for grant funding awarded through the contracts. Subawards were used to hire additional staff for DPH’s COVID-19 Containment Program, for duties that included determining who is eligible to receive federal assistance, achieving the objectives established by the program, making programmatic decisions, and adhering to all applicable federal program compliance requirements. Recommendation: DPH management should reevaluate the criteria used to determine whether subaward recipients are classified as subrecipients or contractors. Additionally, management should ensure that risk assessments and required monitoring procedures are performed for all entities classified as subrecipients. Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the Office of the City Controller’s finding. PDPH maintains a process to identify subrecipients during the contracting process. Contracts with subrecipients include federal compliance language. The three entities identified in this finding, including Concilio, Urban Affairs Coalition (UAC), and Public Health Management Corporation (PHMC), should have been classified as vendors and not subrecipients. These entities were not responsible for programmatic decision-making. This error has been corrected in subsequent contracts. Despite the misclassification, appropriate vendor monitoring was conducted, including supervision of staff hiring and monitoring and reconciliation of monthly invoice packages. Contact Person: Jessica Caum, Director, Department of Public Health, 215-685-6731 Naomi Mirowitz, Performance and Compliance Officer, Department of Public Health, 215-964-5050
Finding 2024-007 U.S. Department of Health and Human Services Assistance Listing Number 93.137 – Community Programs to Improve Minority Health Grant Program Material Weakness and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes, 2023-007, 2023-008, 2023-009 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)),and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 1 selection, the City was not able to provide support showing evidence of the risk assessment performed prior to granting funds to the subrecipient and of the monitoring of the subrecipient during the year. Additionally, various information related to the funding source and the grant were missing on the memorandum of understanding (assistance listing number, federal department grantor, single audit requirements, etc.) Cause: The program has had significant employee turnover and there was a lack of documentation of these policies and procedures. Program management does not have knowledge of the process used to select subrecipients. Monitoring procedures performed were not documented and reports submitted by the subrecipients were not reviewed. Effect or Potential Effect: Failure to explicitly state federally-imposed requirements and regulations may result in noncompliance by the subrecipient. Selecting subrecipients without a formal evaluation process and performing minimal monitoring procedures increases the risk of noncompliance for the City and could lead to a loss of funding if the subrecipients are deemed noncompliant. Questioned Costs: Unknown. Recommendation: Program management should revise subaward agreements to specifically note the requirements and regulations of the Uniform Guidance, as noted in Section 200.331(a). Additionally, program management should develop standardized procedures for selecting and granting subawards. These procedures should be formalized and maintained for future reference. Brief minutes of progress meetings should be taken to show that monitoring is taking place. All reporting by the subrecipient should be reviewed by management of the program. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Federal agency: U.S. Treasury Department Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.019 Pass-Through Agency: Prince William County Pass-Through Number(s): 117203461 Award Period: 3/11/2022 – 12/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: Uniform Guidance §200.331 and §200.332 requires pass-through entities to ensure that subrecipients comply with Federal statutes, regulations, and the terms and conditions of their subawards. This includes performing subrecipient monitoring procedures such as reviewing financial and programmatic reports, following up on identified deficiencies, and issuing management decisions for audit findings. Condition: The auditee did not have documented policies or procedures in place to monitor subrecipients for compliance with federal award requirements. Specifically, the auditee did not perform or document required subrecipient monitoring activities, such as review of financial or programmatic reports, verification of compliance with applicable federal requirements, or follow-up on subrecipient audit results, for the fiscal year under audit. Questioned costs: $2,246,007; Questioned costs reflect only funds passed through to subrecipients and exclude amounts expended directly by the auditee. Context: Due to the absence of subrecipient monitoring controls and procedures, unable to determine whether subrecipients complied with applicable federal requirements. As a result, the entire amount of subrecipient expenditures was considered noncompliant and was reported as questioned costs. This finding affected all subawards under the program. Cause and Effect: Management did not establish or maintain formal subrecipient monitoring policies and procedures and did not assign sufficient resources or oversight responsibility to ensure compliance with Uniform Guidance requirements governing subrecipient monitoring. As a result of the lack of subrecipient monitoring, the auditee was unable to ensure subrecipient compliance with federal award requirements. This resulted in material noncompliance, a material weakness in internal control over compliance, and material questioned costs totaling approximately $2.2 million, representing the full amount of federal funds passed through to subrecipients under the program. This finding resulted in an adverse opinion on compliance for the major program. Repeat Finding: Yes; 2023-002 Recommendation: We recommend that the Alliance establishes a formal policy for sub-recipient monitoring in accordance with requirements outlined in 2 CFR §200.331 and 2 CFR §200.332 to ensure its sub-recipients are properly monitored. Views of responsible officials and planned corrective action: There is no disagreement with the audit finding. The Alliance performed certain monitoring activities; however, documentation was not retained in a manner sufficient to demonstrate compliance with Uniform Guidance requirements. This policy has since been revised to save the monitoring documentation to the grant management software. Contact person responsible for corrective action: Lisa Wolf, Board Chair. Anticipated Completion Date: June 30, 2026
Material Weakness Finding No. 2024-002: Subrecipient Monitoring U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Identification of Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding No. 2023-002. Recommendation We recommend that the Organization incorporate and adhere to the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards.
FINDING REFERENCE NUMBER 2024-039 FEDERAL PROGRAMS (ALN – 93.558) TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS 2022G996117 (Federal Award Year: 10/1/2021 – 9/30/2022) 2023G996117 (Federal Award Year: 10/1/20212 – 9/30/2023) 2401PRTANF1 (Federal Award Years: 10/1/2023 through 9/30/2026) ADMINISTRATION ADMINISTRATION FOR SOCIOECONOMIC DEVELOPMENT OF THE FAMILY (ADSEF, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT REPORTING – SPECIAL REPORTS FOR FFATA TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA In accordance with 2 CFR Part 170, establishes that recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-Federal entity or Federal agency must report each obligating action to http://www.fsrs.gov. For subaward information, report no later than the end of the month following the month in which the obligation was made. STATEMENT OF CONDITION During our testing of reporting compliance requirements applicable to the TANF program, we noted that Administration for Socioeconomic Development of the Family (ADSEF) did not submit the required FFATA reports for applicable first-tier subawards equal to or exceeding $30,000 to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Based on the amounts reported in the SEFA, certain entities receiving TANF funds were identified as subrecipients as defined in 2 CFR 200.1. However, ADSEF does not have appropriate internal control procedures related to reporting requirements and, as a result, did not identify the related payments as reportable subawards under 2 CFR Part 170. Consequently, ADSEF could not provide evidence that the required FFATA subaward reports were submitted accurately and within the required reporting timeframe. QUESTIONED COSTS None. PERSPECTIVE INFORMATION ADSEF consultants identified entities for which they understand are subrecipients. There were a total of twenty (20) agreements/contracts executed during fiscal year 2023-2024 that could be subject to FFATA reporting requirements, however, ADSEF cannot certify if all are subrecipients. According to the audit procedures performed, the agency did not have an established process for identifying first-tier subawards subjects to reporting or for submitting the corresponding FFATA notification through the FSRS. The deficiency is systemic, since the situation stemmed from ADSEF's general process and methodology for classifying entities that receive TANF funds and determining the applicability of FFATA reports. STATEMENT OF CAUSE ADSEF did not establish adequate policies, procedures, and internal controls to properly evaluate and determine whether entities receiving TANF funds should be classified as subrecipients or contractors in accordance with 2 CFR 200.331. As a result, applicable subawards subject to FFATA reporting requirements were not identified and reported to FSRS. POSSIBLE ASSERTED EFFECT Failure to report first-tier subawards in FSRS results in noncompliance with Federal transparency and reporting requirements established under 2 CFR Part 170 and may impair public transparency and accountability over the use of Federal funds. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS We recommend that ADSEF strengthen its internal control procedures over FFATA compliance to ensure that all applicable first-tier subawards equal to or exceeding $30,000 are identified, monitored, and reported timely and accurately in FSRS in accordance with 2 CFR Part 170 requirements.
Finding 2024-003 Internal Control and Compliance over Subrecipient Monitoring (Material Weakness) Information on the Federal Program: Assistance Listing Number(s): 17.258, 17.259, 17.278 Federal Program Name: Workforce Innovation and Opportunity Act (WIOA) Federal Agency: U.S. Department of Labor Pass-Through Entity: California Employment Development Department Federal Award Number and Award Year: AA211008/AA311008/AA411008/AA411009/AA411010 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.331 Requirements for pass-through entities (2 CFR 200.331): All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.; (1) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (2) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (a) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During our testing of the Imperial County Workforce Development Office’s (ICWDO) provisions for subrecipient monitoring under the WIOA Cluster, we noted two (2) of the two (2) subrecipient selected for testing, there was no review or approval over the monitoring procedures performed by ICWDO monitoring staff. The entire population consisted of two (2) subrecipients. Also, the County did not document their evaluation of the subrecipient’s risk of noncompliance. The following information was not provided at the time of the subaward for two (2) of the two (2) subawards selected for testing: o Federal award identification number o Federal award date of award to recipient by the Federal agency o Name of federal awarding agency o Federal Financial Assistance Listing/CFDA Number o Identification of whether the award is research and development Cause: The County’s ICWDO department does not have a formal procedure in place for the department’s review and approval over the monitoring procedures performed by the department over its subrecipients. The ICWDO department did not ensure that the required award information and applicable requirements were communicated to the subrecipients and did not maintain documentation of their evaluation of each subrecipient’s risk of noncompliance. Effect: The County’s ICWDO department did not review and approve monitoring procedures performed over its subrecipients. Additionally, the ICWDO department did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 (a) and 200.332(b). Identification as a Repeat Finding, If Applicable: Yes. See Finding 2023-004. Questioned Costs: No questioned costs were identified. Recommendation: We recommend ICWDO implement policies and procedures in accordance with 2 CFR 200.331(a) 200.332(b) to ensure compliance with subrecipient monitoring requirements and that require the review and approval of the monitoring procedures performed over its subrecipients by a separate individual. View of Responsible Officials and Planned Corrective Action: See separate Corrective Action Plan.
FINDING NO: 2024-025- Improve Subrecipient Monitoring (Repeat 2023-006) STATE AGENCY: Oklahoma Department of Human Services (DHS) FEDERAL AGENCY: Department of Health and Human Services (DHHS) ALN: 93.658 FEDERAL PROGRAM NAME: Foster Care – Titel IV-E FEDERAL AWARD NUMBER: 2301 OKFOST and 2401 OKFOST FEDERAL AWARD YEAR: 2023 and 2024 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition and Context: We judgmentally selected 2 of the 11 subrecipients (18.18%) to determine whether controls were designed and implemented to ensure a risk assessment of the subrecipient was performed by the Pass-Through Entity (PTE) and noted the following: For 2 subrecipients (100%), we determined a risk assessment was performed based on previous year’s performance to determine the appropriate subrecipient monitoring of each subrecipient; however, the date the risk assessments were performed are not documented, the award amount on the risk assessment equals the amount of funds paid during SFY24, and the line items Results of Single Audit are dated in July 2024. We randomly selected 4 of the 11 subrecipients (36.36%) to determine if all requirements imposed by the PTE on the subrecipient so that the federal award was used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposed on the subrecipient in order for the PTE to meet its own responsibility for the federal award and we noted: • Two of four (50%) subawards, cost allocation plans were not received per the contract. • Four of four (100%) subawards, the statement of work had insufficient detail to determine if deliverables were met. For both of our samples, we reviewed the subrecipient contracts to determine whether they included information required in accordance with 2 CFR 200.332(b) and we noted: • Two of six (33.33%) subawards did not include the subrecipient name and unique entity identifier • Six of six (100%) subawards did not include the Federal Award Identification Number (FAIN) • Six of six (100%) subawards did not include the Federal Award Date • One of six (17%) subawards did not include the Federal Award project description • Two of six (33.33%) subawards did not include the name of Federal awarding agency, pass through entity (PTE), and PTE awarding official contact information in the award document • One of six (16.67%) subawards did not include the ALN (Assistance Listings number) and title as required on the contract • Six of six (100%) subawards did not include identification of whether the award was for Research & Development • Three of six (50%) subawards did not include an indirect cost rate negotiated between the subrecipient and the Federal Government and also did not include an appropriate rate determined by the PTE in collaboration with the subrecipient. Cause: Management does not properly understand the program requirements. This is a prior audit finding dating back to SFY2017; however, DHS Management has shown some corrective action has been implemented to address identifying the award and applicable requirements and monitoring as required in 2 CFR 200.332. DHS does not have adequate controls in place to properly monitor subrecipients to ensure the contractual obligations are met. Effect: DHS is not in compliance with the monitoring requirements for this program. Therefore, subrecipients may not administer federal funds in accordance with program requirements. Recommendation: We recommend DHS further modify its subrecipient agreements and related documentation to ensure all required award information is provided and that any additional requirements imposed by DHS in their subrecipient agreements are complied with. Further, the contract should explicitly state the program duties to be performed by the subrecipient. Additionally, we recommend DHS perform risk assessments on all subrecipients at the start of the fiscal year to determine the level of monitoring necessary. Criteria: 45 CFR §75.303(a) states in part: “The Non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per 2 CFR §200.1 Definitions defines subaward as “Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract [emphasis added].” 2 CFR §200.332 Requirements for pass-through entities states in part “All pass-through entities must: … (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the passthrough entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency; (4) Indirect cost rate: (i) An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. (c) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a federal awarding agency) … (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Paragraph 7 of the agency’s subrecipient contract states in part “Sub-Recipient will provide a cost allocation plan to OKDHS within thirty (30) calendar days of this Agreement being signed. In the event there are any changes to the Cost Allocation Methodology, Sub-Recipient will notify OKDHS of those changes before submitting any affected quarterly claim invoice. Views of Responsible Official(s) Contact Person: Kayla Urtz, Director of Internal Audit Anticipated Completion Date: 9/30/2026 Corrective Action Planned: The Department of Human Services agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report.
FINDING NO: 2024-014 (Repeat 2023-026) Strengthen Internal Controls Over Monitoring of Subrecipient Agreements and Expenditures STATE AGENCY: State of Oklahoma, Office of Management and Enterprise Services (OMES) FEDERAL AGENCY: US Department of Treasury ALN: 21.023 FEDERAL PROGRAM NAME: Emergency Rental Assistance (ERA 1 and ERA 2) FEDERAL AWARD NUMBER: ERA028 and ERAE0259 FEDERAL AWARD YEAR: 2024 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Condition and Context: Oversight and management of the ERA program has been transferred at the beginning of SFY25 from the office of the Director of Budget, Policy and Gaming Compliance to the OMES Grant Management Office (OMES-GMO), which has staff with several years of grant experience. OMES-GMO recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. The GMO implemented a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. SAI began working on the SFY24 audit of the ERA program in the fall of 2025 and the OMES GMO actively facilitated all of our audit requests (to the extent the subrecipients would provide the requested information), worked to implement corrective action for all prior year audit findings and implemented oversight and monitoring activities over the remaining unexpended ERA grant funds. However, because these activities did not start until after the SFY24 audit period, most of the prior year audit findings remained uncorrected during the SFY24 audit period resulting in repeat findings. The following issues associated with monitoring occurred prior to the current OMES GMO assuming responsibility for the oversight of the State of Oklahoma ERA program. The State of Oklahoma entered into an agreement with a non-profit entity, Communities Foundation of Oklahoma (CFO), to administer the ERA program for the State of Oklahoma. SAI reviewed the agreement for this entity during our SFY 2021 audit and determined the agreement constituted a subrecipient relationship that would be subject to Part M Subrecipient Monitoring requirements, which was communicated to OMES in findings from the SFY 2021 audit sent to OMES 9/7/2022, The subrecipient expended $8,936,468 in Federal funds during State Fiscal Year (SFY) 2024; however, the Office of Management Enterprise Services (OMES) did not perform any subrecipient monitoring procedures; . OMES advanced program funds, totaling $343,173,664.69, to CFO during SFY 2021-SFY 2023 for which CFO did not submit any documentation to support program expenditures incurred. While OMES did obtain summary information related to rental and utility payments and housing stability payments made for reporting purposes, OMES did not request, obtain or review any support for administrative or program costs to ensure that the costs were attributable to providing financial assistance and housing stability services to eligible households. 1 See SEFA Footnote 10 explaining why the ERA program is not a major program for 2024. However, even though the program is not material based on State of Oklahoma expenditures, we noted Material Weaknesses and Significant Deficiencies in Internal Controls, Material Noncompliance, and Questioned Costs greater than $25,000 when auditing the subrecipient expenditures. Therefore, these deficiencies will be reported under non-major program classification. Until the end of FY2025, OMES did not have a process in place to review potential fraud identified by the subrecipients and ensure that the agency’s response was adequate. OMES also did not have a process to ensure subrecipients were adequately evaluated for the types of fraud that may occur or identifying fraud risk factors applicable to the ERA program. OMES was unable to provide documentation to support that a risk assessment was performed in which each subrecipient would have been verified to have maintained an active status in the SAM.gov system, and that subrecipients were not suspended or disbarred. Cause: OMES did not timely take corrective action to address prior year findings from the SFY 21 - SFY 23 audits. OMES did not timely take corrective action to require OMES personnel to obtain, review, approve, or maintain adequate supporting documentation for all subrecipient expenditures. The required corrective action would have included transferring administration of the ERA grant to the GMO office or other personnel with the experience and expertise to administer Federal grant funds before the majority of the ERA funds were expended by the subrecipient. Additionally, OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control over the Federal award to provide reasonable assurance that the non-Federal entity was managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effect: Inadequate risk assessment procedures and the lack of appropriate monitoring resulted in non-compliance with award terms and mismanagement of award funds. Furthermore, noncompliance increases the risk of Federal claw backs, which impacts state dollars. OMES decisions to delay appropriate oversight of the ERA program and to delay implementation of adequate corrective action until after the majority of grant funds have been expended by a subrecipient increases the risk that funds may not be successfully recouped from the subrecipient and greatly increases the risk that the state taxpayers will be required to pay back accumulated questioned costs of over $23 million in unallowable costs. Subrecipient agreements were not maintained for the period of performance of the Federal award. As a result, Federal funds may not have been authorized, increasing the risk of improper use of Federal funds. Recommendation: We recommend that the OMES GMO continue implementing the corrective action plan established in FY 2025 to provide proper oversight and monitoring of ERA program expenditures. Criteria: 2 CFR § 200.303(a) states in part, “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR § 200.332 states in part, “All pass-through entities must: … b. evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as: 1. The subrecipient's prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). … d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: … 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. … f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” 2 CFR § 200.334 states in part, “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.” 2 CFR § 200.337 states in part, “(a) Records of non-Federal entities. The Federal awarding agency, Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and discussion related to such documents.” U.S Department of the Treasury Emergency Rental Assistance Grantee Award Form (8) (a-b) Compliance with Applicable Law and Regulations, states in part, a. “Recipient agrees to comply with the requirements of Section 501 and Treasury interpretive guidance regarding such requirements. Recipient also agrees to comply with all other applicable federal statutes, regulations, and executive orders, and Recipient shall provide for such compliance in any agreements it enters into with other parties relating to this award. b. Federal regulations applicable to this award include, without limitation, the following: i. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions as Treasury may determine are inapplicable to this Award and subject to such exceptions as may be otherwise provided by Treasury. Subpart F -Audit Requirements of the Uniform Guidance, implementing the Single Audit Act, shall apply to this award… iii. Reporting Subaward and Executive Compensation Information, 2 C.F.R. Part 170, pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part 170 is hereby incorporated by reference.” The US Department of Treasury Emergency Rental Assistance (ERA) FAQ #31 states in part “Grantees should require recipients of funds under ERA programs, including tenants and landlords, to commit in writing to use ERA assistance only for the intended purpose before issuing a payment. Grantees are not required to obtain documentation evidencing the use of ERA program funds by tenants and landlords. Grantees are expected to apply reasonable fraud-prevention procedures and to investigate and address potential instances of fraud or the misuse of funds that they become aware of.” Management Response Contact Person: Brandy Manek, OMES Director of Budget, Policy & Gaming Compliance Anticipated Completion Date: Completed Corrective Action Planned: The Oklahoma Office of Management and Enterprise Services (OMES) partially concurs with the finding. See corrective action plan located in the corrective action plan section of this report. Auditor’s Response: With regard to the assertion that the State “could not take corrective action prior to the FY2024 audit began”, we respectfully disagree per the following reasons: As a recipient of the Federal ERA award, the State of Oklahoma is responsible for understanding the terms and conditions of the award and to ensure the ERA award is administered in accordance with federal regulations, which includes subrecipient monitoring activities. In May of 2021, the State first received Coronavirus Relief Fund (CRF) Audit Finding # 2020-083 related to the State’s lack of subrecipient monitoring activities and Audit Finding # 2020-081 related to the State’s failure to obtain adequate supporting documentation for subrecipient expenditures prior to paying for goods and services. The same individual served as the State’s audit contact for both the CRF award and the ERA award and, therefore, the State could have begun implementing required subrecipient monitoring activities and ensuring adequate supporting documentation was obtained from the subrecipient in May of 2021. Although the SFY 2021 Single Audit Report was not actually released until June 2023, the SFY 2021 Single Audit Report was originally scheduled for publication near the end of September of 2022, and, on September 6, 2022, SA & I provided OMES Audit Finding # 2021-081 which included the following subrecipient monitoring issues SA & I had identified as of that date: “OMES entered into agreements with two non-profit entities to administer the ERA program for the State of Oklahoma: Communities Foundation of Oklahoma (CFO) and Restore Hope Ministries (RHM). SAI reviewed the agreements for these two entities and determined that both agreements constituted a subrecipient relationship that would be subject to Part M Subrecipient Monitoring requirements. We noted that OMES failed to perform any required subrecipient monitoring activities, specifically: • OMES did not provide the subrecipients with appropriate documentation to identify the required Federal award identification information per 2 CFR section 200.331(a)(1). • OMES did not perform a risk assessment that met the compliance requirements. The risk assessment performed did not include any assessment of the risks related to the payments made by the subrecipient for rental, utility, and administrative payments, and it was not designed to identify transactions or types of payments at higher risk and then identify additional monitoring procedures to address those risks. • OMES did not perform any during the award monitoring activities with regard to the rental and utility applications, housing stability and payments approved and paid by the subrecipients, or the administrative expenditures actually incurred by the subrecipients. OMES provided subrecipients advance payments based off expected program rental and utility expenditures for the month and then paid administrative costs on a set percentage of program funds advanced. OMES did not review any supporting documentation related to actual program expenditures for rental and utility assistance, housing stability activities, or administrative expenditures actually incurred by the subrecipients. While OMES did obtain summary information related to rental and utility payments and housing stability payments made for reporting purposes, OMES did not review any actual administrative expenditures to ensure that the administrative costs were attributable to providing financial assistance and housing stability services to eligible households. • OMES provided in excess of $750,000 in Federal funds to both CFO and RHM during SFY 2021; however, OMES did not have a process for identifying and tracking the total amount of federal funds received by subrecipients and notifying the subrecipients of the Single Audit requirements and date the audit would be due. • OMES did not obtain any financial records and supporting documents from the subrecipients that would support the actual expenditures incurred by the subrecipients.” Given the State first received similar findings for the SFY 2020 CRF award in May of 2021 (12 months before the start of SFY 2023 and 24 months before the start of SFY 2024), the State did have sufficient and timely notice to make full corrective actions prior to this SFY 2024 audit and even prior to the SFY 2023 audit. It is the position of our office that the State could have greatly reduced the amount of ERA questioned costs incurred over the past few years if the State had not waited about three and a half years (May 2021 to January 2025) from when SA & I first provided applicable findings to start implementing corrective action.
Reference Number: 2024-004 Federal Program Titles: Temporary Assistance for Needy Families (TANF) Foster Care – Title IV-E Federal Assistance Listing Numbers: 93.558 93.658 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: N/A Name of County Department: Health and Human Services Category of Finding: Subrecipient Monitoring Material Noncompliance and Material Weakness Criteria In accordance with Title 2 of the Code of Federal Regulations (CFR) § 200.332, all pass-through entities (PTE) must: (a) Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: (1) Federal award identification. (i) Subrecipient’s name (must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated in the subaward; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414). (2) All requirements of the subaward, including requirements imposed by Federal statutes, regulations, and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency; (4) Indirect cost rate: (i) An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. The indirect cost rate may be either: (A) An indirect cost rate negotiated between the pass-through entity and the subrecipient. These rates may be based on a prior negotiated rate between a different pass-through entity and the subrecipient, in which case the pass-through entity is not required to collect information justifying the rate but may elect to do so; or (B) The de minimis indirect cost rate. (ii) The pass-through entity must not require the use of the de minimis indirect cost rate if the subrecipient has an approved indirect cost rate negotiated with the Federal Government. Subrecipients may elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d). (5) A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements for the pass-through entity to fulfill its monitoring requirements; and (6) Appropriate terms and conditions concerning the closeout of the subaward. (c) Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (d) If appropriate, consider implementing specific conditions in a subaward as described in § 200.208 and notify the Federal agency of the specific conditions. (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Depending upon the pass-through entity’s assessment of the risk posed by the subrecipient (as described in paragraph (c) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing site visits to review the subrecipient’s program operations; and (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. (g) Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient’s audit, site visits, or other monitoring necessitate adjustments to the pass-through entity’s records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. Condition During our audit of the TANF and Foster Care programs, we noted that the draft schedule of expenditures of federal awards did not include expenditures passed through to subrecipients. Upon inquiry, program management did not have a clear understanding of the difference between a subrecipient and a contractor and, as a result, had not identified, reported on, or monitored subrecipients. Subsequently, using the criteria in 2 CFR § 200.331 Subrecipient and contractor determinations, program management performed an analysis of payments made to contractors and identified the following: • TANF: two entities that received a total of $293,289 in payments during FY2023-24. • Foster Care: two entities that received a total of $139,607 in payments during FY2023-24. Of these we sampled two subrecipients from TANF and one subrecipient from Foster Care. Because program management did not previously identify any entities as subrecipients, the County did not comply with the requirements of subrecipient monitoring as follows: Both TANF and Foster Care: • The County could not demonstrate that a verification was performed to determine that the entities were not excluded or disqualified from receiving federal funds for all three subrecipients. While one entity’s contract included reference to 2 CFR Part 376 Nonprocurement, Debarment and Suspension, it did not specifically include a self-certification clause. • TANF Contracts: One contract was deficient and did not identify the contract as a federally funded subaward and did not include the required elements outlined in § 200.332 (b). The contract for the other entity was more prescriptive and included most of the elements in § 200.332 (b) but also did not have current language referencing the Uniform Guidance, which was effective in 2014 (Contract date was December 4, 2019), and instead referred to outdated requirements under OMB Circular A-133. One contract did not address indirect costs. One contract did not address provisions to permit the County as the grantor to access the entity’s records to audit or fulfill other monitoring responsibilities. Both contracts did not address the terms and conditions concerning the closeout of subawards. Both TANF and Foster Care: • The County did not perform the required fraud risk and risk of noncompliance assessment to determine the appropriate level of monitoring. • The County has not developed and documented a formal subrecipient monitoring plan. Upon inquiry, program management provided a bulleted list of their monitoring activities; however, reviews, meetings, action items, and follow-up were not formally documented to demonstrate the activities were performed. • The County received single audit reports from the two subrecipients identified; however, the County did not reconcile the amounts reported to its records. Foster Care TANF #1 TANF #2 Total Subrecipient’s SEFA $ 0 $ 101,886 $ 232,499 $ 334,385 County SEFA 105,530 43,689 249,560 399,884 Variance (105,530) 58,197 (17,601) (65,499) Cause Program staff were not aware of the requirements to evaluate and classify entities as contractor or subrecipient and did not understand the need to formalize a subrecipient monitoring program in accordance with §200.332. The cause can be partially contributed to turnover in the County’s Health and Human Services Department. Effect Failure to evaluate and identify subrecipients will cause the County to be out of compliance with its oversight responsibilities resulting in the potential for federal funds to be used inappropriately. Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Failure to have a formal monitoring program that includes risk assessment will result in the County inadequately monitoring the activities of subrecipients and hold them accountable to complete corrective action plans for identified noncompliance. Questioned Costs None. Context Fiscal year 2024 payments to the subrecipients were as listed: • TANF - $293,289 or 9% of total program expenditures. • Foster Care - $139,607 or 6% of total program expenditures. The sample was not a statistically valid sample. Identification as a Repeat Finding Previously reported as Finding 2023-003. Recommendation We recommend the County consider the following: 1. Provide comprehensive training to program managers on how to assess if an entity meets the criteria of a subrecipient as defined in § 200.331. 2. Formalize a subrecipient monitoring program based on the criteria in § 200.332. 3. Design a subrecipient agreement template to include all the elements required by 2 CFR § 200.332(b). Incorporate the use of the template in the contracting requirements for all departments receiving federal funds. 4. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR § 200.332(b).
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Criteria or specific requirement: According to §200.331 Requirements for pass-through entities of two CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition and Context: During our testing, we noted the Organization did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. Questioned costs: N/A Cause: The Organization was unaware of the subrecipient monitoring requirements. Also, the Organization lacks established internal controls and procedures for monitoring pass-through funds to subrecipients to ensure compliance with applicable compliance requirements. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. The auditor noted instances of material noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients or that the grant funds are not used for authorized purposes or in line with the grant terms and conditions. Recommendation: We recommend that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Management Response: Management has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.
Program: Emergency Rental Assistance Program Federal Agency: Department of Treasury (DOT) AL #: 21.023 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M – Subrecipient Monitoring Criteria Per OMB Uniform Guidance, 2 CFR sections 200.331 (d) through (f), a pass-through entity (the City) must “monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.” Also, per the City’s Grant Award Manual (City policy) regarding the Site Monitoring Plan of all subrecipients – “staff shall conduct and document at least one site visit annually.” Condition Management did not annually monitor “all” subrecipients as required by the Federal regulations and City’s policy. Cause Management does not have controls and processes in place to ensure that all subrecipients are monitored in accordance with the City’s policy. Effect Subrecipients may not be complying with the terms and conditions of the subaward or achieving program performance goals. Questioned Costs $4,644,629 Is the finding a repeat finding No Recommendations We recommend management establish a process to ensure all subrecipients are monitored as stated in the Federal regulations and City’s policy. Views of Responsible Officials/ Planned Corrective Actions Management agrees with the finding. See Corrective Action Plan on Organization’s letterhead.