Finding 2023-001 – Subrecipient Monitoring U.S. Department of Health and Human Services Foster Care Title IV-E – ALN 93.658 Pass-through Agency: Pennsylvania Department of Human Services Program: Foster Care Title IV-E Condition: The County has internal controls in place to monitor subrecipients of Foster Care Title IV-E funding, however, not all required procedures are being performed. The County did not ensure that Foster Care Title IV-E subrecipients were notified via contract or letter of the subaward ALN and amount that was paid during the year. Additionally, the County does not have a formally documented risk assessment process for evaluating subrecipients’ risks of non-compliance. As part of the monitoring process, the County obtained and reviewed annual audit reports for a portion of, but not all of, the subrecipients in a timely manner in order to ensure the subrecipient complied with the Foster Care Title IV-E Instructions and Requirements. Criteria: The Pennsylvania Department of Human Services (PA DHS) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Additionally, 2 CFR section 200.332(a) requires pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN as well as notify the subrecipient of the amount that was paid during the year. Cause: Procedures are in place over subrecipient monitoring, however the procedures to ensure that subrecipients are notified of their subaward including ALN number and amount are not adequate. The County does not have procedures in place to document the assessment of risk for subrecipients. In addition, the County does not have procedures in place to adequately review all subrecipient audits or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenses being incurred by County subrecipients. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subawards and implement a process to ensure all subrecipient audits are reviewed and deficiencies be followed up on. In addition, we recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits. Questioned Costs: Unknown Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate corrective action plan.
Department of Labor Workforce Pathways for Youth, Federal Assistance Listing Number 17.261 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance with Federal Awards Criteria: The Organization should have effective internal controls in place over the submission of FFATA per 2 CFR 200.332. Condition: During the FY2023 Audit, it was noted that the Organization did not submit the necessary FFATA reports. It was noted that the FFATA was completed on August 28, 2024. Context: The Organization did not submit FFATA reports within the required time period for any of their subrecipients. Questioned Costs: N/A Cause/Effect: FFATA report was not submitted within the required time period due to management unintentionally overlooked the requirement as the hiring of the Director of Grants and Compliance during 2023 was subsequent to the execution of the subrecipient agreement and thus the Organization is not in compliance with the grant. Identification of Repeat Finding: N/A Recommendation: The Organization should ensure that it has controls in place to monitor compliance with FFATA reporting. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report.
Finding 2023-006: Foster Care Title IV-E - Subrecipient Monitoring (Significant Deficiency) Federal Programs: Foster Care - Title IV-E and Temporary Assistance for Needy Families Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Pennsylvania Department of Human Services ALN Number: 93.658 Federal Award Year: December 31, 2023 Prior Year Finding: 2022-003 Criteria: Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and other means. Condition/Context: For two of the four providers monitored during the program’s fiscal year, the County Child and Youth Services department’s results and findings were communicated to the providers at the conclusion of the review procedures, however providers did not submit a written corrective action plan. For one of the providers monitored, results of monitoring could not be located of review. Cause: Providers on-site monitoring was completed and the results were communicated to the providers in writing. Notice that a corrective action plan was needed in response was not given to two of the providers. Effect: Lack of written corrective action plan limits the County Child and Youth Services department’s ability to monitor that the providers takes timely and appropriate action to address deficiencies pertaining to the federal award. Questioned Costs: There are no questioned costs associated with this finding. This is not a statistically valid sample. Recommendation: Providers that receive findings as a result of their on-site monitoring should submit a corrective action plan to the County. Views of Responsible Officials and Planned Corrective Actions: The County Child and Youth Services department started requiring a corrective action plan for all subrecipients with findings as a result of their on-site monitoring in 2023 that include the entity’s plan to correct the errors noted, individual responsible and timeline for corrections to be implemented. Finding noted are for monitoring completed in January and March 2023, prior to the requirement of written corrective action plans being implemented.
Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
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.
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