Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and maintain effective internal control over federal awards. Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have documented internal controls over compliance. Cause: There were no written procedures over allowable costs and when changes in management and accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Costs charged to the federal program may not be allowable. Context: 60 out of 739 disbursement transactions were tested. Repeat Finding: No Recommendation: Internal controls over compliance for allowable activities and cost principles should be documented and design and document procedures over allowable cost principles. Views of Responsible Officials: Management agrees with the finding and will implement procedures to document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and maintain effective internal control over federal awards. Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have documented internal controls over compliance. Cause: There were no written procedures over allowable costs and when changes in management and accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Costs charged to the federal program may not be allowable. Context: 60 out of 739 disbursement transactions were tested. Repeat Finding: No Recommendation: Internal controls over compliance for allowable activities and cost principles should be documented and design and document procedures over allowable cost principles. Views of Responsible Officials: Management agrees with the finding and will implement procedures to document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Agriculture Federal Award Identification Numbers: 58-5090-2-037 2022-38624-38368 2021-38640-34714 2020-38640-31522 2022-38640-37486 2023-51300-40959 2021-68012-35917 2019-68012-29852 2020-68012-31934 2021-49400-35592 NR225F48XXXXG006 Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1, 2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through August 31, 2025, and January 1, 2022 through December 31, 2026 Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes the required federal award identification information, all requirements imposed by the pass-through entity on the subrecipient, any additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements, and appropriate terms and conditions concerning the closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: No subaward agreements included all required information. No risk assessments were performed and documented. No monitoring procedures were performed other than reviewing invoices to be paid and an audit report received. Cause: Internal controls have not been designed, implemented, and documented in written procedures. Internal controls are not designed or implemented to ensure subrecipient agreements include the required information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure monitoring takes placed as planned, and to verify and document whether subrecipients that expended $750,000 or more in federal awards is audited in accordance with the Uniform Guidance. Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the award and costs charged may be unallowable and disallowed. Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and documented. Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.600, Department of Health and Human Services, Head Start and Covid-19: Head Start ARP Federal Award Identification Number and Year: 05CH011937-03-03, 05HE000989-01-01 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted that 3 out of 3 subaward agreements tested did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.600, Department of Health and Human Services, Head Start and Covid-19: Head Start ARP Federal Award Identification Number and Year: 05CH011937-03-03, 05HE000989-01-01 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted that 3 out of 3 subaward agreements tested did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 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 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 by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2023, the subrecipient received $180,658 ($31,619 - ALN 93.044, $149,039- ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2022-008 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2023, the subrecipient received $180,658 ($31,619 - ALN 93.044, $149,039- ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2022-008 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-004 – Subrecipient Monitoring Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Pass-through entities are required to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients are notified of their requirement to receive an audit and take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients and 2 CFR section 200.332(a) required pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN and amount that was paid during the year. Condition: The Organization did not comply with subrecipient monitoring requirements around risk assessment monitoring, audit requirement language, including federal assistance listing number, within their contract, and review of subrecipient single audit compliance. Questioned Costs: Unknown Cause: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure subrecipient monitoring includes proper risk assessment and monitoring of single audit compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.