Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Finding 2023-002: Failure to Notify Subrecipients of Federal Funding Condition Found: Carle did not communicate required federal program information to subrecipients the Illinois SOR2 program. During our testing of 2 subrecipient awards, we noted the subaward document did not include most of the required elements, including but not limited to: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Amounts passed through to subrecipients under the SOR2 program totaled $201,863 during the year ended December 31, 2023. Criteria or Requirement: Per 2 CFR 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at 2 CFR 200.332 (1) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include implementing risk assessment procedures required by Uniform Guidance and ensuring monitoring procedures are performed and documented in accordance with established policies and procedures. Cause: In discussion with Carle management, internal controls were not effectively implemented at the organizational level or cascaded to department leadership. The templates used for subawards was not reflective of the required communications. Possible Asserted Effect: Failure to communicate ALNs at the time of disbursement can hamper the subrecipient’s ability to correctly prepare their schedule of expenditures of federal awards. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend Carle evaluate its subaward documents for federal awards and ensure that they include all required elements. Views of Carle management: Management agrees with the finding. Ann Campen had conversations with all the sub-awardees and provided them with the information required. Staff will email the sub-awardees with an “addendum” by the end of calendar year 2024.
Program Information: Substance Abuse and Mental Health Services Administration (ALN #93.493) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Federal Compliance Requirement: M. Subrecipient Monitoring – The pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). Condition: For 1 out of 4 Clubs selected, the Alliance could not provide evidence that a site visit was performed. Cause: The site visit in question was performed by the prior Alliance Executive Director, who did not transfer the documentation of the site visit to the Alliance before ending her employment there. Effect or Potential Effect: We were unable to independently verify that the site visit was performed and the Alliance complied with subrecipient monitoring requirements. Questioned Costs: None. Context: Through discussion with the Organization’s management, they assert that site visits were performed as required, however, documentation of the site visit was not maintained and we were unable to independently verify that the site visit occurred. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the Organization enhance its policies and procedures over subrecipient monitoring to ensure that evidence of monitoring procedures is maintained. Views of Responsible Officials and Planned Corrective Actions: The Alliance performed site visits as required, and will maintain documentation of these going forward to provide verification that these occurred in accordance with the contract and our documented subrecipient monitoring procedures.
2023-004: U.S. Department of Agriculture Soil and Water Conservation Assistance Listing #10.902 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Non-Compliance Grant Award Number: NR230436XXXXC017 Criteria: The OMB Compliance Supplement (2 CFR 200.331) requires that pass-through entities (PTE) disbursing federal funds to subrecipients have a formalized policy for identifying the subrecipient meets the applicable requirements, for evaluating risk, for monitoring subrecipient activity, and for ensuring accountability of For-Profit Subrecipients, if applicable. As part of the risk assessment, entities must ensure subrecipients are not suspended or debarred. During monitoring activities, the PTE is required to obtain the subrecipients’ audit reports so that any findings can be evaluated by the PTE’s management. Condition: Several required elements per 2 CFR 200.331 being absent from the subrecipient agreements, including: - Subrecipients’ unique entity identifier - Federal award date of award to Wallowa Resources by the USDA - ALN number and dollar amount made available by the USDA Wallowa Resources was unable to provide support that subrecipients were assessed for suspension and debarment during the risk assessment. Cause: Wallowa Resources did not have a formalized policy for subrecipient monitoring which resulted in several required elements per 2 CFR 200.331 being absent from the subrecipient agreements, lack of retention for work performed during the risk assessment and monitoring activities. Effect: Certain compliance elements related to subrecipient monitoring not met as a result of ineffective controls. Questioned Costs: None Context/Sampling: There were four subrecipients within the scope of this audit, of which 75% were tested and the above-noted items were consistent. Repeat Finding from Prior Year: No Recommendation: We recommend Wallowa Resources implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332. Views of Responsible Officials: Management agrees with the finding.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Federal Program Information: Education Stabilization Fund (ALN 84.425U) Criteria: The Code of Federal Regulations (CFR) Section 200.332 requires the pass-through entity (PTE) to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section Massachusetts Alliance of Boys & Girls Clubs, Inc. Schedule of Findings and Questioned Costs For the Year Ended December 31, 2023 26 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The subaward agreements did not include the required federal provisions. Cause: The Alliance was unaware of the requirement to include the required federal provisions in the subaward agreements. Effect or Potential Effect: The Alliance was not in compliance with the subrecipient requirements outlined in the agreement and in 2CFR200.332. Recommendation: We recommend that the Alliance update subaward agreements to include all federal provisions required to be communicated by the grant and also 2 CFR 200.332. Views of Responsible Officials: The Alliance will implement internal controls and administrative oversight to ensure subrecipient monitoring requirements are being followed and adequately documented.
Program Information: 84.287C Twenty-First Century Community Learning Centers; Lottery for Education: Afterschool Programs (LEAP) Criteria: (CFR) Section 200.332 requires a pass-through entity (PTE) to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The Organization did not execute awards with its subrecipients until after funds were disbursed to the subrecipient. Cause: Lack of administrative oversight with respect to subrecipient monitoring requirements. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Questioned Costs: None Context: The Organization did not execute awards with its subrecipients until April 2024. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the Organization enhance its policies and procedures over subrecipient monitoring to ensure subaward agreements are executed at the time of the subaward. Views of Responsible Officials: The Alliance will implement additional administrative oversight to execute subaward agreements in a timely manner.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. 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, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. 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, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. 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, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.
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 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 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 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 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 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.