Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI 2022-032, MI 2022-048, and MI 2023-027 Pass through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Uniform Guidance at 2 CFR 200.332, the pass through entity (SMART) must monitor the activities of a subrecipient as necessary to ensure that the subawards comply 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. Condition - The Authority did not provide sufficient evidence that there was adequate monitoring of subrecipients. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - It was identified in the 2025 triennial review that the Authority's procedures and documentation of subrecipient oversight was not adequate. The Authority had two subrecipients during fiscal year 2025, and one of the subrecipients was not adequately monitored based on the funding received. Cause and Effect - The Authority did not provide sufficient evidence for adequate monitoring of subrecipients during the triennial review. Recommendation - We recommend the Authority strengthen subrecipient procedures and maintain evidence that these procedures were performed according to schedule. Views of Responsible Officials and Corrective Action Plan - The Authority is in agreement with this finding. The Authority has reviewed and corrected procedures related to monitoring subrecipients.
Finding 2025 - 001 Lack of Subrecipient Monitoring Procedures – Subrecipient Risk Assessments Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: Bureau of Population, Refugees and Migration Overseas Refugee Assistance Programs East Asia; Foreign Assistance for Programs Overseas Assistance Listing Numbers:19.523 and 98.001 Pass-through Entities: JSI Research & Training Institute, Inc. and RTI International Award Identification Number and Year: SPRMCO24CA0083, 2024; 7200AA22CA00011, 2022 and 72066923CA00003, 2023 Criteria or Specific Requirement: According to 2 CFR § 200.332(c), pass-through entities are required to: “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.” This risk assessment must consider factors such as the subrecipient’s prior experience with similar awards, results of previous audits, new personnel or systems, and the extent of Federal monitoring. Condition: BRAC USA did not adequately document the results of it's risk assessment procedures of its subrecipients prior to issuing subawards, as required by 2 CFR § 200.332(c). During our review of two subawards issued during the audit period, we noted that management did not formally document any evaluation of subrecipient risk related to program compliance, financial stability, or internal controls. Cause: The entity had not developed or implemented formal procedures to adequately document subrecipient risk prior to making subawards. Management was not aware of the documentation requirement or had not prioritized its implementation. Effect or Potential Effect: Without documenting subrecipient risk assessments, BRAC USA cannot ensure that the level of subrecipient monitoring is appropriate to mitigate risks of noncompliance or misuse of Federal funds. This increases the likelihood of unallowable costs, noncompliance with Federal regulations, and potential questioned costs. Questioned Costs: Costs associated with qualitative monitoring measures are not identifiable. Context: During our audit, we examined subawards for two subgrantees for which total expenditures aggregated $1,683,098 (approximately 67% of the total Federal expenditures passed through to subrecipients). Identification as a Repeat Finding, if applicable: Not a repeat findingRecommendation: The entity should establish and implement written procedures to perform and document subrecipient risk assessments prior to awarding Federal funds. The procedures should include standardized criteria—such as prior audit results, experience with similar programs, financial stability, and management capacity—to determine risk levels and guide monitoring activities.
2025-003 Lack of Formal Subrecipient Monitoring Program Name/Assistance Listing Number: 93.788 Opioid STR Federal Agency: Department of Health and Human Services Type of Finding: Significant Deficiency Compliance Requirement: Subrecipient Monitoring Criteria: According to 2 CFR §200.332 (Requirements for Pass-Through Entities), a pass-through entity must monitor the activities of subrecipients as necessary to ensure that federal funds are used for authorized purposes and in compliance with applicable statutes, regulations, and terms and conditions of the Federal award. Required monitoring includes, but is not limited to, the following: a. Reviewing financial and programmatic reports; b. Performing risk assessments of subrecipients; c. Following up on deficiencies identified through audits or reviews; and d. Ensuring subrecipients have required audits under 2 CFR §200.501. Lack of documented subrecipient monitoring constitutes noncompliance with Uniform Guidance. Condition: During our walkthrough and review of the Organization’s grant management processes, we noted that the Organization does not have formal subrecipient monitoring policies or procedures in place. While a monitoring memo exists, it documents only an informal process and does not provide structured oversight. Specifically: - No risk assessments, monitoring checklists, or follow-up documentation were maintained. - There is no formalized, structured process or standard for overseeing subrecipient activities. - Required monitoring under 2 CFR §200.332 could not be performed. Cause of Condition: Management has not developed formal policies and procedures for subrecipient monitoring or consistent documentation standards. Potential Effect of Condition: Noncompliance: Failure to monitor subrecipients increases the risk of noncompliance with Uniform Guidance requirements. Questioned Costs: Federal program expenditures passed through to subrecipients may become subject to questioned costs if insufficient oversight results in unallowable or unsupported charges. Financial & Operational Risk: The Organization may be exposed to reputational or financial consequences, including funding restrictions, if the lack of monitoring persists. Questioned Cost: Not quantifiable. Recommendation: We recommend the Organization develop and implement formal policies and procedures for subrecipient monitoring, including: a. Conducting and documenting subrecipient risk assessments; b. Establishing structured monitoring procedures, such as periodic reviews, report evaluations, and follow-ups; c. Maintaining written documentation of all monitoring activities; and d. Implementing policies to ensure consistent oversight of subrecipient performance and compliance. Description of the Nature and Extent of Issues Reported: The Organization did not perform or document any formal subrecipient monitoring activities during the fiscal year. This constitutes noncompliance with 2 CFR §200.332. Management Response: Management concurred with the finding. In the future, the organization will require midyear and year-end impact reports from each grant subrecipient.
Subrecipient Monitoring Departments of Education Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Condition: During our audit, we found that RAED did not have proper subrecipient monitoring documentation related to approvals and communication of subaward terms and conditions. Criteria: 2 CFR section 200.332, Requirements for pass-through entities, requires RAED to communicate subaward terms and conditions with subrecipient and to monitor the subawards for authorized purposes in compliance with Federal statutes, regulation and the terms and conditions. Cause: Communication to subrecipients about terms and conditions of the subaward was not sent out during the fiscal year. It was also noted that there was a missed approval of a reimbursement request during staff turnover. Effect: RAED is not incompliance with Federal Award Programs. Recommendation: We recommend RAED review their procedures in place to determine if any improvements can be made to ensure compliance with subrecipient monitoring. Management Response: There is no disagreement with the audit finding.
Finding 2025-002: Subrecipient Monitoring Criteria: The Uniform Guidance (2 CFR §200.332) requires a non-Federal entity to monitor the activities of its subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Specifically, the Sponsoring Organization is required to perform specific monitoring activities, including site visits, for its CACFP subrecipients (centers/homes). To ensure that these required monitoring activities are occurring timely and correctly, the Sponsoring Organization's internal controls include a requirement for monthly meetings between the Program Manager and the Monitoring Specialist to review the status of subrecipient monitoring. Condition: During the review of internal controls related to subrecipient monitoring, it was noted that the required monthly meetings between the Program Manager and the Monitoring Specialist were not consistently performed throughout the fiscal year. Specifically, for the 12-month period tested, the required monthly reviews were not documented for 3 out of 12 months. Cause: The lapse in the required monthly reviews was attributed to staff turnover in the program office and competing priorities that diverted staff time away from this control activity. Effect: The lack of consistent management oversight through the required monthly meetings increases the risk that mandatory subrecipient monitoring activities (e.g., required site visits, review of subrecipient documentation) could be delayed, missed, or performed inadequately. This could result in non-compliance by the subrecipients going undetected, potentially leading to inaccurate claims and funds being used for unauthorized purposes. Questioned Costs: None noted. Context: This is the first year this finding has been reported. The internal control deficiency appears to be a breakdown in the execution of the established procedure rather than an absence of a control. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: We recommend that management reinforce the importance of this control and implement a documented process to ensure that the monthly meetings between the Program Manager and the Monitoring Specialist occur consistently. This should include establishing a recurring meeting schedule and requiring documentation (e.g., signed meeting minutes, checklist) that demonstrates the review of monitoring status took place each month, even during periods of staff turnover or high-priority competing demands.
Finding 2025-003: Subrecipient Monitoring Criteria: The Uniform Guidance (2 CFR §200.332) requires a non-Federal entity to monitor the activities of its subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Furthermore, the Organization's policy and/or CACFP regulations governing the Sponsoring Organization require an initial on-site review of each new center or Family Child Care (FCC) provider within the first 28 calendar days of program operation. This is a critical component of initial subrecipient monitoring to ensure program integrity and compliance with Federal requirements. Condition: The Sponsoring Organization did not consistently perform the required initial on-site review for new subrecipients (centers and FCC providers) within the mandatory 28-day timeframe. A sample of 40 new centers/FCC providers was selected for testing. Four (4) of the 40 subrecipients (10%) did not have their initial on-site review completed within the first 28 days of operation. The delays in conducting the initial reviews ranged from 6 to 23 days past the required 28-day deadline. Cause: The cause appears to be an inadequate internal control or process to ensure initial review scheduling and completion are prioritized and managed to meet the 28-day deadline, potentially due to competing demands or staffing limitations. Effect: Failure to conduct initial on-site reviews within the required timeframe weakens the Sponsoring Organization's internal controls over subrecipient monitoring and oversight. Timely initial reviews are essential for early identification and correction of compliance issues, proper training, and ensuring new centers/FDCH providers operate in accordance with Federal CACFP requirements from the outset. Questioned Costs: None noted. Context: This is the first time this issue has been noted as a finding. The Sponsoring Organization performed the required reviews; however, they were completed after the regulatory deadline. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: The Sponsoring Organization should strengthen its internal controls and monitoring procedures to ensure that all new centers and FCC providers receive the required initial on-site review within the 28-day mandatory timeframe. This should include: 1. Establishing a formal process with documented timeframes for assigning and completing initial reviews immediately upon a new site's approval. 2. Implementing a system to track and alert monitoring staff of the 28-day deadline for each new subrecipient. 3. Providing targeted training to monitoring staff to emphasize the importance of timely initial reviews and the associated regulatory deadlines.
Finding: 2025-002 Subrecipient Monitoring (Significant Deficiency) Federal Agency(ies): United States Department of Agriculture Federal Program(s): Partnerships for Climate-Smart Commodities Assistance Listing Number(s): 10.937 Pass-through Entity (if applicable): N/A Award Identification Number and Year: NR233A750004G045 (2023) Criteria or Specific Requirement: Per 2 CFR 200.332 Requirements for pass-through entities: Pass-through entities must clearly identify to subrecipients the award information, including the Assistance Listing number, subrecipient’s UEI, Federal award identification number, and Federal award project title (§200.332(a)(1)). Pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate subrecipient monitoring (§200.332(b)). Pass-through entities must monitor the activities of subrecipients as necessary to ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward (§200.332(d)). Condition: During our testing of subrecipient monitoring, we noted several deficiencies: 1. Subaward agreements were structured more like subcontracts rather than subrecipient agreements and did not include all elements required under 2 CFR 200.332(a), such as the subrecipient’s UEI and Assistance Listing number. 2. Subrecipients were required to submit periodic invoices for reimbursement instead of financial reports detailing costs incurred by budget line item, cumulative expenditures, cash receipts, and cash balances. 3. Pre-award risk assessments were completed; however, the assessments were undated, preventing the audit team from verifying that they occurred prior to subaward execution. Additionally, the monitoring procedures described in policy were not clearly linked to assessed risk levels, and in certain instances, subrecipients with no prior Federal grant management experience were assigned a “low risk” classification. Cause: These conditions occurred due to a lack of formalized procedures to align subrecipient agreements, reporting requirements, and monitoring activities with the specific requirements of 2 CFR 200.332. Management relied on existing subcontract templates and internal policies that were not fully updated to reflect Uniform Guidance requirements. Effect or Potential Effect: Failure to properly structure subaward agreements, and obtain adequate financial reporting, increases the risk that subrecipients may not comply with Federal statutes and regulations. Questioned Costs: N/A Context: We tested a statistically valid sample of subawards charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if Applicable: Yes, repeat of Finding 2024-002Recommendation: We recommend that management: Update subaward agreement templates to include all elements required under 2 CFR 200.332(a). Require subrecipients to submit periodic financial reports by budget line item, cumulative expenditures, cash receipts, and cash balances, rather than invoices alone. Revise pre-award risk assessment procedures to include dating and ensure that results are documented prior to subaward execution. Strengthen policies to ensure monitoring procedures are explicitly linked to risk assessment results, with higher levels of oversight required for subrecipients new to Federal grant management.
Findings and Questioned Costs Relating to Federal Awards: 2025-001 Compliance Finding: Subrecipient Monitoring-Audit Verification. Federal Agengy: Department of the Treasury. Pass-through Entity: SC Rural Infrastructure Authority. Federal Program: Coronavirus State and Local Fiscal Recovery Funds(CSLFRF)-Water Capacity Improvments. Assistance Listing Number: 21.027. Criteria. In accordance with 2 CFR 200.332(g) a pass-through entity must verify that a subrecipient is audited as required by subpart F. Subpart F: 200.501 Audit Requirements. (a) Audit required. A non-Federal entity that expends $1,000,000 ($750,000 prior to the 2024 uniform Guidance (UG) revisions) or more during the non-Federal enity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. Condition. Cherokee County did not adequately verify that the subrecipient obtained the required single audit or program specific audit in accordance with 2 CFR 200.332. Although Cherokee County was aware that the subrecipient would be subject to audit requirements based on federal expenditures, Cherokee County did not obtain or otherwise confirm receipt of the required audit report by the applicable submission deadline of September 30, 2025. Upon further inquiry it was determined that the subrecipient did not have a single audit or program-specific audit by September 30, 2025. Cause. The County did not perform sufficient follow-up procedures to confirm subrecipient compliance with single audit requirements after being notified that the subrecipient would be subject to audit for the year ended December 31, 2024. Effect. Failure to verify receipt of the required audit prevented Cherokee County from complying with their policies and procedures and with federal regulation in a timely manner. Recommendation. We recommend that Cherokee County enhance its subrecipient monitoring procedures to include documented follow-up and verification that subrecipients subject to single audit requirements submit the required audit reports within the applicable timeframes, in accordance with 2 CFR 200.332.
Federal Program: Temporary Assistance for Needy Families (TANF) (93.558). Criteria: 2 CFR 200.332(d) requires pass-through entities to monitor the activities of subrecipients to ensure compliance with federal statutes, regulations, and the terms and conditions of the subaward. Required monitoring activities include reviewing financial and performance reports, following up on deficiencies, and ensuring timely corrective action. Condition: The Council did not perform required monitoring procedures for subrecipients as required by Uniform Guidance: Cause: The Council lacked formal procedures and controls for tracking and reviewing subrecipient audit reports and for documenting follow-up on identified deficiencies. Effect: There is an increased risk that subrecipients may not comply with federal requirements, which could result in unallowable costs, questioned costs, or other noncompliance with federal statutes and regulations. Questioned Costs: None. Context: This finding was noted in 3 out of 4 subrecipients for the fiscal year ended June 30, 2025 with a total of $124,302 paid to subrecipients. Repeat Finding: No. Recommendation: We recommend the client implement and document formal procedures to ensure all required subrecipient monitoring activities are performed in accordance with Uniform Guidance, including obtaining and reviewing subrecipient audit reports and following up on any identified deficiencies. Views of Responsible Officials: Management concurs with the finding and will implement corrective action.
Finding Reference Number: 2025-001 Federal Program: CFDA 93.959– Block Grants for Prevention and Treatment of Substance Abuse Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Service Florida, Inc. Award Year: FY 2025 Criteria: Per 2 CFR §200.332(d), pass-through entities must monitor the activities of subrecipients to ensure that federal awards are used for authorized purposes and in compliance with laws, regulations, and the provisions of the subaward. Monitoring includes reviewing performance and financial reports required by the subaward agreement. Condition: The pass-through entity conducted appropriate monitoring activities for the subrecipient Bradford Community Coalition, Inc., including communication and oversight consistent with federal requirements. However, the subrecipient did not submit the required monitoring report by the established deadline. As of the audit report date, the report remained outstanding. Cause: While the pass-through entity fulfilled its monitoring responsibilities, the subrecipient failed to comply with reporting requirements in a timely manner. Effect: The absence of the monitoring report limits the pass-through entity’s ability to fully verify that the $39,406 in federal funds was used in accordance with applicable regulations. This may result in questioned costs due to insufficient documentation. Questioned Costs: $39,406 Recommendation: We recommend the pass-through entity continue its monitoring efforts and implement additional follow up procedures to ensure timely receipt of required reports. The entity should also consider revising subaward agreements to include stronger enforcement mechanisms for noncompliance. Views of Responsible Officials: The organization monitored the subrecipient in accordance with federal guidelines and has documented its oversight activities. We are working with the subrecipient to obtain the overdue report and have updated our procedures to escalate follow-up actions when reports are delayed.
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Condition: For 2 out of 2 selections, the unique identifier number and federal award identification number were not included in the grant agreement. For 2 out 2 selections, evidence that the prior year Single Audit Report was reviewed was not provided. 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 nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. 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; and (2) The results of previous audits including whether or not the subrecipient receives a Single Audit. (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: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance for subrecipient monitoring. Effect: The subrecipient could not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls to ensure grant agreements include the unique identifier number and federal award identification number. We also recommend a process to ensure that the single audit of subrecipients are reviewed timely. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. 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.
U.S. Department of Labor (DOL) AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 2 out of 2 selections, the unique identifier number on the notice of award did not agree with the subrecipient's active registration UEI on SAM.gov. For 2 out of 2 selections, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 2 out of 2 selections, evidence that the prior year Single Audit Report was reviewed was not provided. 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 nonfederal 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; and (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. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause: The Mayor’s Office of Employment Development (MOED) did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: MOED may not be in compliance with the subrecipient monitoring requirements of its grants. 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.
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Condition: The unique entity identifier (UEI) was not included in the grant agreements for 1 out of 1 subrecipient grant agreement selected for testing. 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; and (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. Cause: The Baltimore County Department of Health (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.
U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Condition: The unique entity identifier (UEI) was not included in the grant agreements for 5 out of 6 subrecipient grant agreement selected for testing. 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; and (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. Cause: The Baltimore County Department of Health (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.
U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Condition: The unique entity identifier (UEI) was not included in the grant agreements for 2 out of 5 subrecipient grant agreement selected for testing. 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 nonfederal 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; and (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. 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.
U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Condition: There was no evidence that the City verified whether the subrecipient was suspended and/or debarred from receiving federal funds for 3 out of 40 subrecipients selected for testing. The City did not have current subrecipient grant agreements for 3 out of 40 subrecipients selected for testing. The unique entity identifier (UEI) was not included in the grant agreements for 3 out of 40 subrecipient grant agreements selected for testing. The Federal Award Identification Number (FAIN) was not included in the grant agreements for 8 out of 40 subrecipient grant agreements selected for testing. The UEI was incorrect in the grant agreement for 1 out of 40 subrecipient grant agreements selected for testing. 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 nonfederal 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; and (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. (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. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause: The City did not maintain adequate documentation of the requirements included in Uniform Guidance for subrecipient monitoring. Effect: The subrecipient could not be in compliance with Uniform Guidance. 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 2025.003 - Subrecipient Monitoring - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: Head Start Cluster, 93.600 Federal Award Identification Number and Year: 01CH011268-05-01 (2024), 01CH012890-01-01 (2024), 01CH011268-05-03 (2024) Name of Pass-through Entity (if applicable): N/A Criteria Per 2 CFR 200.332 (Requirements for pass-through entities) a pass through entity must, among other things, evaluate each subrecipient's risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and 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 CLC did not properly monitor its subrecipient in accordance with Uniform Guidance requirements. The agreement with the subrecipient referred to outdated polices that were replaced by the Uniform Guidance (Circulars A-87, A-110, A-133) and did not include all required elements which included, but is not limited, to the Assistance Listing Number, Unique Identifying Number. A review was not performed of the use of program funds or the subrecipient's audited financial statements and Uniform Guidance report. Cause The Financial Policies and Procedures Manual was not followed. The manual also needs to be updated to include the updated requirements of the Uniform Guidance and require documentation of review of compliance with requirements. Effect or Potential Effect Failure to perform required risk assessments and to adequately monitor subrecipients may result in the subrecipient not properly administering the federal program in accordance with laws, regulations, and the grant agreement. Questioned Costs None Context During our testing, we noted CLC did not perform subrecipient monitoring procedures over subrecipients with respect to the Head Start Cluster Program during the year ended June 30, 2025. Amounts passed through to subrecipients totaled $284,791 for the year ended June 30, 2025. Identification as a Repeat Finding This is not a repeat finding. Recommendation Management should review the Uniform Guidance requirements for subrecipient monitoring and update their policy manual as appropriate. We recommend CLC develop and implement a standardized checklist that outlines all subrecipient monitoring compliance requirements. The checklist should clearly identify the individual responsible for implementing each requirement and the individual responsible for reviewing compliance, along with documentation of that review. Views of Responsible Officials Children’s Learning Centers of Fairfield County, Inc. concurs with this finding. Management will update its Financial Policies and Procedures Manual and subaward templates to align with current Uniform Guidance requirements, including all required subaward elements (such as Assistance Listing Number, UEI, award identification, and applicable compliance requirements). CLC will implement a standardized subrecipient monitoring checklist covering risk assessment, review of invoices and programmatic reports, verification of allowable costs, confirmation and review of subrecipient audit requirements and Uniform Guidance reports (as applicable), and documentation of management review. Monitoring will be documented and reviewed by senior management on at least an annual basis and more frequently based on risk.
FINDING 2025-003 Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Federal Agency: Department of Education Federal Program: Teacher and School Leader Incentive Grants Assistance Listings Number: 84.374 Federal Award Numbers and Years (or Other Identifying Numbers): Year 2-3, Year 3-4 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance related to the Teacher and School Leader Incentive Grants (TSL) funds passed through to subrecipients. The School Corporation received and passed through to subrecipients $6,143,393 of TSL funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The School Corporation did not enter into an agreement with the subrecipients. As such, there is no agreement between the School Corporation and the subrecipients that clearly identifies the award as a subaward or includes all the required data elements. In addition, the School Corporation did not have any policies or procedures in place to evaluate the subrecipients' risk of noncompliance or to monitor the activity of the subrecipients. Per inquiry of the School Corporation, it was determined an evaluation of the risk of noncompliance for the subrecipients was not completed, nor did the subrecipients' files support any such evaluation. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF DECATUR TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "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). . . ." 2 CFR 200.332 states: "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 passthrough 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; INDIANA STATE BOARD OF ACCOUNTS 20 METROPOLITAN SCHOOL DISTRICT OF DECATUR TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can 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 have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (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 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; INDIANA STATE BOARD OF ACCOUNTS 21 METROPOLITAN SCHOOL DISTRICT OF DECATUR TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) 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; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. INDIANA STATE BOARD OF ACCOUNTS 22 METROPOLITAN SCHOOL DISTRICT OF DECATUR TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations." Cause The School Corporation's management was not aware of the requirements for subrecipient and subaward monitoring compliance. Thus, the School Corporation had not implemented its system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Subrecipient Monitoring compliance requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls, including segregation of duties, to evaluate the subrecipients' risk of noncompliance and adequately monitor the subrecipients. Additionally, policies and procedures should be implemented to ensure appropriate reviews, approvals, and oversight are taking place, as needed, to evaluate and monitor its subrecipients. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Condition: The City entered into a written agreement with a subrecipient; however, the agreement did not include language requiring the subrecipient to compliance with the Uniform Guidance. As a result, the subrecipient was not formally notified of its responsibility to adhere to federal administrative, cost, and audit requirements. Criteria: 2 CFR §200.332(a) requires pass-through entities to ensure that subaward agreements include all required federal award information and clearly identify applicable federal statutes, regulations, and terms and conditions, including compliance with Uniform Guidance (2 CFR Part 200). Cause: The City had a preexisting agreement with an entity who later became a subrecipient of federal grant pass-through funds. The City did not amend their agreement to include the required components after receiving the grant nor report the funds as federal revenues or expenditures in the City’s financial statements. Effect or Potential Effect: Without a formal subaward agreement, the pass-through entity lacks assurance that the subrecipient understands and complies with applicable federal requirements, increasing the risk of noncompliance, improper use of federal funds, and questioned costs. The subrecipient may also not be aware of their responsibility to report the related federal expenditures on the subrecipient’s schedule of expenditures of federal awards. Questioned Costs: None. Recommendation: We recommend that the City identify all federal expenditures and passthrough awards and notify all subrecipients of their receipt of federal awards by identifying the award granted, specific compliance requirements passed-through and other requirements of 2 CFR 200.332. Management’s Comments Regarding Corrective Actions Planned: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of specific compliance requirements under the Uniform Guidance (2 CFR Part 200). We will make sure that all future subrecipients of pass-through federal grants are notified in writing of the responsibility to adhere to federal administrative, cost, and audit requirements.
Federal Program - Research and Development Cluster Assistance Listing Numbers - Various Federal Agency - All Research and Development Sponsor Award Number - Various Award Period - Various Criteria or Specific Requirement – Subrecipient Monitoring - Management is responsible for verifying that subrecipients expected to be audited as required by CFR part 200, subpart F, met this requirement. (2 CFR 200.332(g)) Condition - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed during the year. Cause - Turnover of University personnel responsible for subrecipient monitoring. Questioned Costs - There were no questioned costs as a result of this finding. Effect - While management did follow established controls to determine whether subrecipients used the Federal awards for authorized purposes and complied with Federal statutes, regulations and the terms and conditions of the sub award, by not confirming whether subrecipients had received required audits, management may not become aware of subrecipients with audit findings. Context - Management reported that subrecipient monitoring procedures as it relates to confirming subrecipients met audit requirements had not been completed for all ten subrecipients during the year. Identification as a Repeat Finding - No. Recommendation - We recommend management bring subrecipient audit documentation current and complete training with responsible individuals to ensure future compliance.
Finding 2025-003 (Material Weakness) Program: Housing Opportunities for Persons with AIDS Federal Agency: United States Department of Housing and Urban Development (HUD) AL #: 14.241 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: N/A Type of Compliance Finding: M) Subrecipient Monitoring Criteria 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 The City did not provide evidence supporting compliance with this requirement. Cause The City failed to 1) evaluate the results of subrecipient’s previous audits including whether or not the subrecipient received a single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward was audited as a major program; and 2) have the Subrecipient address the identified findings in the contract monitoring report according to the response timeframe outlined in the report; to ensure quality programming that benefits the clients. Effect The City may not be compliant with HUD, which could result in the City not receiving federal assistance or repayment of grant funds. Questioned Costs None Context N/A Is the finding a repeat finding No Recommendations We recommend the City ensure Subrecipients respond to all corrective action plans by the required timeframes outlined and 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.
Assistance Listing Numbers: 21.027 Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Maricopa County Pass-Through Grantor Identifying Number: None Award Year: November 1, 2021 through September 30, 2026 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e) & (g) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC's system of internal controls did not include a process to monitor the subrecipients' financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria and ensure that subrecipients take corrective action on single audit findings. Questioned Costs: N/A Context: In a population of five subrecipients, we noted that for all five subrecipients, while AACHC performed several of the required subrecipient monitoring tasks, AACHC did not monitor subrecipient activity through reviewing financial and performance reports, verify that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. This is deemed to be a material weakness in internal control over compliance. Effect: The system of internal controls was not properly designed to include a process to review financial and performance reports, verifying that subrecipients are audited if the meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Cause: AACHC was not aware of the requirements within the Uniform Guidance for pass-through entities to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Identification of Repeat Finding: Not a repeat finding. Recommendation: AACHC should update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. We also recommend AACHC regularly attend trainings on the Uniform Guidance to ensure they are knowledgeable of the required compliance procedures. Views of Responsible Officials and Planned Corrective Actions: Management of AACHC concurs with the finding. See Corrective Action Plan.
Assistance Listing Numbers: 93.332 Program: Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges Federal Agency: Department of Health and Human Services Pass-Through Agencies: N/A Pass-Through Grantor Identifying Number: NN/A Award Year: August 27, 2021 through August 26, 2024; August 27, 2024 through August 26, 2027 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e) & (g) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC's system of internal controls did not include a process to monitor the subrecipients' financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria and ensure that subrecipients take corrective action on single audit findings. Questioned Costs: N/A Context: In a population of twelve subrecipients, we noted that for all twelve subrecipients, while AACHC performed several of the required subrecipient monitoring tasks, AACHC did not monitor subrecipient activity through reviewing financial and performance reports, verify that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. This is deemed to be a material weakness in internal control over compliance. Effect: The system of internal controls was not properly designed to include a process to review financial and performance reports, verifying that subrecipients are audited if the meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Cause: AACHC was not aware of the requirements within the Uniform Guidance for pass-through entities to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Identification of Repeat Finding: Not a repeat finding. Recommendation: AACHC should update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. We also recommend AACHC regularly attend trainings on the Uniform Guidance to ensure they are knowledgeable of the required compliance procedures. Views of Responsible Officials and Planned Corrective Actions: Management of AACHC concurs with the finding. See Corrective Action Plan.
2025-001 - Internal Control over Compliance and Compliance with Subrecipient Monitoring Requirements Information on the Federal Program: United States Department of Treasury Assistance Listing Number: 21.027 Assistance Listing Name: Coronavirus State and Local Fiscal Recovery Fund Pass-Through Entity: Prince George’s Country Maryland Pass-Through Entity Number: 52-6000-998 Award Period: February 28, 2024 through June 30, 2025 Criteria– In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with 2 CFR §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. 2 CFR §200.332(b), Requirements for pass-through entities, indicates that pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and that the subaward document includes the best available information provided within 2 CFR §200.332(b)(1). Condition – During our testing of the two subrecipients under this program, we noted that management did not determine whether the subrecipients were suspended or debarred prior to entering into the agreement with the subrecipients or when the subaward agreements were amended. Additionally, the agreements between The Community Foundation and the subrecipients did not contain certain key information, such as the assistance listing number, as required by 2 CFR §200.332(b)(1). Context – During our review of The Community Foundation’s compliance with the Uniform Guidance requirements, we noted that there were two subrecipients under the applicable federal program. Both subrecipients were selected for testing, resulting in a 100% examination rather than a sample-based approach. Upon identification of compliance errors, management subsequently verified the status of the subrecipients in the System for Award Management (“SAM”) to confirm that neither was suspended nor debarred. We reviewed supporting documentation from SAM and confirmed that both subrecipients were not suspended or debarred. Following the audit procedures, which identified missing data elements required by 2 CFR §200.332(b)(1), management issued communications to each subrecipient, providing the relevant information that had initially been omitted from the subaward agreements. Cause - The Community Foundation’s policies include requirements to determine whether vendors/subrecipients are suspended are debarred when working on Federal programs. The individuals executing the agreements between The Community Foundation and the two subrecipients did not properly follow the procurement policy with respect to checks for suspension and debarment. In addition, the individuals executing the agreements with the two subrecipients did not properly review the regulations and did not identify the need to include the information in 2 CFR §200.332(b)(1). Effect or Potential Effect - The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Questioned Costs - There are no questioned costs. Repeat Finding - This is not a repeat finding from prior year. Recommendation - We recommend that The Community Foundation ensure consistent adherence to its policies and procedures. Given that federal funding is not received on a recurring basis, certain policies and procedures may become outdated. We further recommend that, upon receipt of federal funding in the future, management designate an individual with appropriate knowledge and experience to review applicable federal regulations and update policies and procedures as necessary to maintain compliance. Views of Responsible Officials – Management agrees with the finding and has implemented corrective actions, including verifying subrecipients’ eligibility in SAM.gov before awarding or amending federal subawards, updating subaward templates to meet federal requirements, and revising procurement and cash management policies for compliance. The Controller will act as Compliance Coordinator for future federal funding, overseeing regulation review, staff training, and quarterly compliance checks, with any deficiencies reported to the CFO for prompt resolution. These measures aim to ensure ongoing adherence to federal grant requirements.
2024-001 Significant Deficiency in Internal Controls over Compliance and Compliance, Other Matter – Procurement (suspension and debarment) Agency: U.S. Department of the Interior Program(s) and Federal Award Listing Number(s): Partners for Fish and Wildlife ALN: 15.631 FAIN: FA22AC02756, FA23AC02476 New or Repeat: New Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Per 2 CFR Part 180, as referenced in 2 CFR Part 1400, for any contract expected to total $25,000 or more, a recipient of federal funds must confirm that the contractor is not suspended or debarred from receiving federal funds. Per 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds in accordance with 2 CFR 180.300. Condition: SAWC was not able to provide supporting documentation indicating that it had verified that contractors and subrecipients were not suspended or debarred prior to contracting with, or making a subaward to, the entities. Cause: Internal controls were designed, but not sufficiently implemented to ensure that documentation of the check for suspension and debarment was retained. Effect: SAWC could have contracted with, or made a subaward to, an entity that was suspended or debarred. Context: We tested 100% of the procurement population. For three of the three contractors/subrecipients tested, we were not able to verify that SAWC confirmed the contractor/subrecipient was not suspended or debarred prior to entering into the transaction. Questioned costs: There are no questioned costs associated with this finding. Recommendation: We recommend SAWC consider either collecting a certification regarding suspension and debarment from contractors/subrecipients or adding a suspension and debarment clause or condition to contracts and subawards. View of responsible officials: Management concurs with this finding, see corrective action plan.
2024-001 Significant Deficiency in Internal Controls over Compliance and Compliance, Other Matter – Procurement (suspension and debarment) Agency: U.S. Department of the Interior Program(s) and Federal Award Listing Number(s): Partners for Fish and Wildlife ALN: 15.631 FAIN: FA22AC02756, FA23AC02476 New or Repeat: New Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Per 2 CFR Part 180, as referenced in 2 CFR Part 1400, for any contract expected to total $25,000 or more, a recipient of federal funds must confirm that the contractor is not suspended or debarred from receiving federal funds. Per 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds in accordance with 2 CFR 180.300. Condition: SAWC was not able to provide supporting documentation indicating that it had verified that contractors and subrecipients were not suspended or debarred prior to contracting with, or making a subaward to, the entities. Cause: Internal controls were designed, but not sufficiently implemented to ensure that documentation of the check for suspension and debarment was retained. Effect: SAWC could have contracted with, or made a subaward to, an entity that was suspended or debarred. Context: We tested 100% of the procurement population. For three of the three contractors/subrecipients tested, we were not able to verify that SAWC confirmed the contractor/subrecipient was not suspended or debarred prior to entering into the transaction. Questioned costs: There are no questioned costs associated with this finding. Recommendation: We recommend SAWC consider either collecting a certification regarding suspension and debarment from contractors/subrecipients or adding a suspension and debarment clause or condition to contracts and subawards. View of responsible officials: Management concurs with this finding, see corrective action plan.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Housing and Urban Development - Home Investment Partnerships Program (ALN 14.239); Direct award and Pass-through: Michigan State Housing Development Authority; All project numbers. Criteria. Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). Cause. The County does not have the proper internal controls in place to ensure all aspects of subrecipient monitoring were performed in accordance with the requirements of the Uniform Guidance. Effect. The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Questioned Costs. None. Recommendation. We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department.
2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Criteria: 2 CFR 200.332 notes, “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. (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; …” Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency was incorrect. The contact information was Education Analytics, Inc., the Organization’s grantor, but should have been Future Forward, Inc. Further, one of the two subawards selected for testing had information missing from the subaward including all requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award. We consider this condition to be an instance of noncompliance relating to the Subrecipient Monitoring compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: Without communication of the required information, subrecipients may overspend award amounts or incur unallowable expenses towards the grant as well as report the incorrect grantor on their schedule of expenditures of federal awards. Recommendation: We recommend the Organization evaluates policies and procedures to ensure all required information is communicated with the subrecipient. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "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." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "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." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "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." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "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." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "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." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.
Subrecipient Monitoring Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLT0790; 2021 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.332 includes requirements such as evaluating the subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the award. Condition: The City did not have documentation of risk assessment procedures performed for two of the four subrecipients tested. Questioned Costs: None. Context: The City of Minneapolis has documented the subaward and subrecipient procedures that its staff are expected to follow. These procedures include the completion of a pre-award risk assessment form and for the form to be maintained in the contract file of the subrecipient. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City is not in compliance with federal regulations. Cause: City staff were not aware of the requirement to perform pre-award risk assessments with subrecipients. Recommendation: We recommend the City ensure that the City’s employees follow its procedures for completing risk assessments when contracting with subrecipients. View of Responsible Official: Concur
Criteria: 2 CFR 200.332 establishes requirements for pass-through entities. Included in these requirements is to 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. Condition: The City did have procedures in place to monitor allowable costs and activities of its subrecipients. However, while conducting a review of expenditures through the monitoring of the Appalachia Community Grant (ACG), the Ohio Department of Development (ODOD), noted that a subrecipient of the City had made unallowable expenditures for the grant. This demonstrates a control weakness in the subrecipient monitoring controls conducted by the City. Context: The City, ODOD, and the subrecipient are working on a way to recover any questioned costs associated with this and these do not represent questioned costs of the City. Effect: There is a significant deficiency in the subrecipient monitoring controls of the City that could allow future unallowable costs or activities at subrecipients, if not improved. Recommendation: We recommend that the City implement stronger monitoring controls including vendor verification and review of invoices for the draw down requests that they receive from their subrecipients.
FINDING 2024-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2024 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The County received an allocation of the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) from the U.S. Department of the Treasury to support its response and recovery from the novel coronavirus. A portion of the County's allocation was then used to subaward funds to another entity (i.e., the subrecipient) to carry out an eligible use. The subaward was provided to the subrecipient via two different subaward agreements. Both subaward agreements were selected for testing. The County, as the pass-through entity, is to clearly identify the subaward and the terms and conditions of the award in the agreement with the subrecipient. During review of the two subaward agreements, it was determined that the Assistance Listings Number (ALN) and Federal Award Identification Number (FAIN) were not included as required. Additionally, the County as the pass-through entity, is to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and terms and conditions of the subaward and that performance goals are achieved. Part of the monitoring requirements include verifying the subrecipient received an audit as required so as to be able to issue management decisions on any findings, as applicable. The County did not have a process in place to obtain and review audits received by the subrecipient. Therefore, the County would not have been able to issue management decisions or ensure timely and appropriate action by the subrecipient. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." 2 CFR 200.332 states in part: "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); INDIANA STATE BOARD OF ACCOUNTS 14 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date . . . 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 passthrough 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 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 used charged) per § 200.414. . . . (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations." Cause The County did not have adequate processes or procedures in place to ensure all of the proper information about the grant was provided to the subrecipient and all required monitoring activities were being conducted. Effect Not providing award identification information to subrecipients could result in the subrecipient not properly reporting the grant on their Schedule of Expenditures of Federal Awards. Furthermore, due to the absence of policies and procedures to monitor the activities of subrecipients, subrecipients could be spending federal funds for unauthorized purposes without the County's knowledge. As such, the County cannot ensure proper accountability and compliance with the program requirements. INDIANA STATE BOARD OF ACCOUNTS 15 HANCOCK COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County strengthen its system of internal controls to ensure that the County verifies that all subrecipients of federal awards receive an audit and that the County receives and reviews any audit reports of the subrecipients. Additionally, we recommended that the County strengthen its system of internal controls to ensure that subaward agreements include all required information that should be known to the subrecipient. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria or specific requirement: Per 2 CFR 200.303(a), the County must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it 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 the ”Standards for Internal Control in the Federal Government” issued by the Comptroller General of the Untied States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Under Uniform Grant Guidance, the County must: • Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain required information including but not limited to: Federal and subaward information, indirect cost rate, and the subrecipient’s unique entity identifier (UEI). (2 CFR 200.332 (b)) • Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. (2 CFR 200.332 (c)) • 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. (2 CFR 200.332 (e)) • Verify that a subrecipient is audited as required by 2 CFR 200.501. (2 CFR 200.332 (g))Condition: Subaward agreement was expired and did not include all required information, nor did the subrecipient have the required UEI. Subaward requirements were not communicated to the subrecipient; therefore, monitoring activities were not effective. Documentation of subrecipient risk assessment or audit verification not available for audit.Questioned Costs: None noted.Context: Audit procedures included testing of the one subrecipient who received a subaward during the year. There were no other subrecipients.Cause: The County’s procedures were not sufficient to ensure the subawards were issued or monitored in compliance with Federal requirements. Internal controls did not prevent or detect the errors.Effect: Failure to properly document required contract information, perform the necessary risk assessments, and document the review of the subrecipient’s single audit may result in noncompliance with grant terms and conditions. Subrecipients may have incomplete Schedules of Expenditures of Federal Awards, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Federal Program Name: Research and Development Cluster: Uniformed Services University Medical Research Projects Federal Agency: U.S. Department of Defense Federal Assistance Listing Number: 12.750 Criteria or Specific Requirement: Subrecipient Monitoring Condition: During testing of subrecipient monitoring, it was noted that the Organization awarded three awards to subrecipients during the year and did not inform these subrecipients of the federal nature of the award at the time of the subaward. Specifically, the required federal award information was not included in the subaward documentation. Effect: Failure to communicate the federal nature of the award may result in subrecipients not being aware of their responsibilities under federal regulations, which could lead to noncompliance with federal requirements. Questioned Costs: None Context: In accordance with 2 CFR section 200.332(a), pass-through entities are required to clearly identify to the subrecipient the federal award information at the time of the subaward. This includes the federal award identification number, the federal awarding agency, the assistance listing number (ALN), and the amount of federal funds obligated. This information was not communicated to the subrecipients Cause: The Organization did not have adequate procedures in place to ensure that all required federal award information was communicated to subrecipients. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure that all required federal award information is included in subaward agreements and communicated to subrecipients at the time of the award. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the comment and will revise policies to communicate all required federal award information to subrecipients.
Finding 2024 – 002: Subrecipient Monitoring Significant Deficiency Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001) Federal Awarding Agency: United States Agency for International Development Awards: • Direct award: Resilient Coastal Community – 72065622CA00010 • Direct award: Urban Sanitation Activity – 72068724CA00001 • Pass-Through from UC Davis – A23-3500-S001 • Pass-Through from Project Concern International – PCI-1203-SG-1600 • Direct award: Reducing Post Harvest Losses through Access to New Technologies - 720BHA22CA00020 Criteria: 2 CFR 200.332 lists requirements for pass-through entities to perform as part of the subrecipient monitoring compliance requirement. This includes performing an evaluation of fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring procedures. 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. 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Context: For each of the six subrecipients selected for testing, the documentation within the 2024 monitoring tracker tool was incomplete, as certain monitoring procedures conducted were not fully recorded and reviewed in the tracker as required by iDE policies. Additionally, one subrecipient underwent a site visit that was not formally documented in a monitoring visit report, resulting in the absence of any record indicating a review had occurred. Overall, subrecipient risk assessments were inconsistently evaluated, leading to insufficient focus on high-risk subrecipients relative to those considered low risk. Cause: Employee turnover and personnel constraints. Effect: Inadequate procedures and controls for subrecipient monitoring may result in noncompliance with applicable federal statutes, regulations, or award terms and conditions. Questioned costs: None Repeat finding? No Recommendation: Management may consider reviewing existing controls over subrecipient monitoring to evaluate their effectiveness in supporting iDE's compliance with 2 CFR 200 requirements. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.