Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: R&D Cluster Federal Award Numbers: Various Federal Award Years: Various Reference: 2023 003 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) 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: (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (2 CFE section 200.332xxi) (b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. BMC does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2023, the BMC passed through $18,031,446 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, BMC has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Single Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified the following: 1. For 4 of 16 subrecipients selected for testwork BMC did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, BMC did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports and review of Single Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by BMC do not include a review to ensure that a risk assessment is performed for each active subrecipient and BMC does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend BMC implement policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). We recommend that BMC enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients.
Finding number: 2023-005 Federal award identification number and year: AL# 21.027 - Coronavirus State and Local Recovery Funds; 2023 Criteria: Pursuant to CFR section 200.332(b), pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: The Unity Council did not perform a risk assessment of subrecipients. This is not a repeat finding. Cause: The Organization does not have a formally documented policy for performing a risk assessment over subrecipients. Effect or potential effect: A risk assessment for purposes of determining the appropriate subrecipient monitoring was not performed. Recommendation: Management should develop a risk assessment policy to evaluate the risk profile of each subrecipient. Factors included during the evaluation can include the subrecipient's prior experience with the same or similar subawards, results of previous audits, whether the subrecipient has new personnel or new or substantially changed systems, and the extent and results of federal awarding agency monitoring. Views of responsible officials: Management is in agreement with the finding and is in the process of developing and documenting a more robust risk assessment process.
2023-004 SUBRECIPIENT MONITORING U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 and CE-00D90119 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes the requirement for the subaward contract to include information such as the federal award identification (Assistance Listing Number (ALN) and name of the federal program), 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 and 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. Condition: Subrecipient awards did not consistently include the required language including the ALN and the pass-through of Federal award requirements. Additionally, the Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: In some cases, the Council used the contract template for a subaward for a state financial assistance program rather than for a Federal award and, as a result, required information and language was missing from the contract. Further, the Council did not update its procedures over subrecipient monitoring to include follow-up of any deficiencies pertaining to the subrecipients’ use of the Federal funding detected through audits, on-site reviews or other means. Effect: Without the required language in the subrecipient contracts, subrecipients may not have the information necessary for them to establish appropriate controls over compliance required by the Federal award and to appropriately identify the Federal award and related expenditures on their Schedule of Expenditures of Federal Awards, if applicable. Additionally, without the monitoring of the results of audits and on-site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. Required language was not included in two of the eight subrecipient awards tested. For one of these two contracts, the contract was originally funded with local share and applied to the Federal award only after the grantor modified the award to allow the Council to apply pre-award expenditures to the grant program. Recommendation: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient.
2023-004 SUBRECIPIENT MONITORING U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 and CE-00D90119 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes the requirement for the subaward contract to include information such as the federal award identification (Assistance Listing Number (ALN) and name of the federal program), 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 and 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. Condition: Subrecipient awards did not consistently include the required language including the ALN and the pass-through of Federal award requirements. Additionally, the Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: In some cases, the Council used the contract template for a subaward for a state financial assistance program rather than for a Federal award and, as a result, required information and language was missing from the contract. Further, the Council did not update its procedures over subrecipient monitoring to include follow-up of any deficiencies pertaining to the subrecipients’ use of the Federal funding detected through audits, on-site reviews or other means. Effect: Without the required language in the subrecipient contracts, subrecipients may not have the information necessary for them to establish appropriate controls over compliance required by the Federal award and to appropriately identify the Federal award and related expenditures on their Schedule of Expenditures of Federal Awards, if applicable. Additionally, without the monitoring of the results of audits and on-site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. Required language was not included in two of the eight subrecipient awards tested. For one of these two contracts, the contract was originally funded with local share and applied to the Federal award only after the grantor modified the award to allow the Council to apply pre-award expenditures to the grant program. Recommendation: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient.
Information on the Federal Program: Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number 21.027 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Controls over Compliance, Modified Opinion Criteria: Title 2 U.S. Code of Federal Regulations (CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Section 200.332, Requirements for pass-through entities, states "All pass-through entities must: (a) ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward; (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 Section 200.208 (Specific conditions); (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved; (f) Verify that every subrecipient is audited as required by 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 Section 200.501. 2 CFR 200.303 states in part: "The non-Federal enity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Condition: The City received a total State and Local Fiscal Recovery Funds (SLFRF) allocation of $3,431,839. In its March, 2022, Project and Expenditures Report, the City elected to use the standard allowance for identifying revenue loss and reported its Revenue Loss Due to Covid-19 Public Health Emergency as $3,431,839. During fiscal year ended September 30, 2023, the City made payments from its SLFRF federal award, totaling $1,600,000, to another local government entity for materials used by the other government for a water line project. The payments were supported by an invoice from the other government, to which were attached copies of invoices submitted to the other government by its vendors. The City reported in its March, 2023, Project and Expenditures Report that the payments were made under the Infrastructure: Drinking water: Transmission & distribution Project Expenditure Category and Subcategory. The City also reported the transactions as a subaward, including identification of the subrecipient, and reported each of the payments to the subrecipient in the Expenditures section, in that Project and Expenditures Report. The City was unable to provide: a copy of the subaward agreement that clearly identified the subaward to the subrecipient as a subaward and that included the information required by Section 200.332(a); supporting documentation that the City evaluated the subrecipient's risk of noncompliance as required by Section 200.332(b); supporting documentation that the City monitored the activities of the subrecipient as required by Section 200.332 (d); and/or supporting documentation that the City verified that the subrecipient was audited as required by Subpart F. Cause: The City did not have adequate internal controls to ensure compliance with the Subrecipient Monitoring compliance requirement. The City's past federal awards experience did not involve or include subawards. Effect or Potential Effect: Noncompliance by the subrecipient may occur due to the subrecipient not being aware of the federal program's requirements and due to the City not sufficiently monitoring the subrecipient. Recommendation: We recommend that management of the City design and implement a comprehensive system of internal controls over federal award compliance, including development of policies and procedures to ensure compliance with the Subrecipient Monitoring compliance requirement. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
2023-004: Significant deficiency over Subrecipient Monitoring Assistance listing number: 97.132 Agency: Department of Homeland Security Program: Targeted Violence and Terrorism Prevention Grant Program Grant Year: 2023 Criteria: According to, § 200.332(a) Requirements for pass-through entities, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes specified 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. Condition: Certain required disclosures, including the assistance listing number, monitoring requirements, and audit requirements, were missing from the subaward. Cause: The subaward was prepared using a format more suited for a contract. Effect: Award requirements may not have been properly communicated to the subawardee. Questioned costs: There were no questioned costs related to this finding. Repeat finding: This is not a repeat finding. Auditor’s recommendation: We recommend all agreements are prepared with the required information before they are finalized. Written processes and control should be developed of subawards and subrecipient monitoring. Utilize a checklist of required communications when completing the agreement to ensure all required elements are included. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
BETH ISRAEL LAHEY HEALTH, INC. AND AFFILIATES Schedule of Findings and Questioned Costs Year ended September 30, 2023 Finding 2023-02 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program: Research and Development Cluster Assistance Listing Number: 93.837 and 93.847 Criteria: Criteria: 2 CFR 200.332(b) requires pass-through entities to evaluate each subrecipient’s risk of non- compliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of 200.332. Further, 200.332 (d) requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: While Joslin Diabetes Center (the Center) has a subrecipient pre-award risk assessment process in place, for 19 of 25 subrecipients, we were unable to verify that the pre-award risk assessment procedures were fully performed. Additionally, while the Center’s risk assessment procedures correspond with a risk-based monitoring plan, for 7 of 25 subrecipients, we were unable to verify that the required monitoring activities were fully completed. We deemed this to be a significant deficiency in internal controls. Cause: As a result of turnover during the fiscal year within Research Finance there was a lack of effective operation of internal controls over subrecipient risk assessment and monitoring activities. Possible Asserted Effect: Without the proper operation of an effectively designed system of internal controls, the internal control system cannot be relied upon to effectively prevent or detect non-compliance. Questioned Costs: None. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Center evaluate its current Subrecipient Monitoring and Management Policy to ensure that the policy reflects each of the risk assessment and monitoring compliance requirements of the Uniform Guidance. Additionally, the results of the Center’s risk assessment and monitoring activities should be formally documented within the tracking log which should then be subject to formal review and approval by an appropriate individual within Research Finance. Views of Responsible Officials: Management acknowledges although tracking logs had been maintained, due to personnel turnover during the year, not all had been reviewed. Management has since created a shared email address to ensure communication and information sharing with all necessary parties. Management is reviewing its current policy for opportunities to strengthen internal controls and current procedures while utilizing available resources.
BETH ISRAEL LAHEY HEALTH, INC. AND AFFILIATES Schedule of Findings and Questioned Costs Year ended September 30, 2023 Finding 2023-02 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program: Research and Development Cluster Assistance Listing Number: 93.837 and 93.847 Criteria: Criteria: 2 CFR 200.332(b) requires pass-through entities to evaluate each subrecipient’s risk of non- compliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of 200.332. Further, 200.332 (d) requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: While Joslin Diabetes Center (the Center) has a subrecipient pre-award risk assessment process in place, for 19 of 25 subrecipients, we were unable to verify that the pre-award risk assessment procedures were fully performed. Additionally, while the Center’s risk assessment procedures correspond with a risk-based monitoring plan, for 7 of 25 subrecipients, we were unable to verify that the required monitoring activities were fully completed. We deemed this to be a significant deficiency in internal controls. Cause: As a result of turnover during the fiscal year within Research Finance there was a lack of effective operation of internal controls over subrecipient risk assessment and monitoring activities. Possible Asserted Effect: Without the proper operation of an effectively designed system of internal controls, the internal control system cannot be relied upon to effectively prevent or detect non-compliance. Questioned Costs: None. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Center evaluate its current Subrecipient Monitoring and Management Policy to ensure that the policy reflects each of the risk assessment and monitoring compliance requirements of the Uniform Guidance. Additionally, the results of the Center’s risk assessment and monitoring activities should be formally documented within the tracking log which should then be subject to formal review and approval by an appropriate individual within Research Finance. Views of Responsible Officials: Management acknowledges although tracking logs had been maintained, due to personnel turnover during the year, not all had been reviewed. Management has since created a shared email address to ensure communication and information sharing with all necessary parties. Management is reviewing its current policy for opportunities to strengthen internal controls and current procedures while utilizing available resources.
Condition: The Organization erroneously recorded a prior year subaward expense as a 2023 subaward expense. This was missed during the Chief Financial Officer's review of subaward invoices and during the Chief Executive Officer's overall review of the Statement of Expenditure of Federal Awards. Criteria: Under 2 CFR §200.332, pass through entities are required to review financial and performance reports of subawardees to ensure accurate reporting and cutoff of invoices related to subawards. Cause: The client does not have sufficient controls in place to ensure accurate reporting and cutoff of invoices related to subawards. Effect: The preliminary Statement of Expenditure of Federal Awards ("SEFA") was understated in the current period. Questioned costs: None. Recommendation: Management should review subaward invoices after year-end to determine proper recording in the proper period to which it relates. Views of responsible officials: Management of the Organization agrees with the finding. Management plans to review and revise existing policies and procedures to ensure accurate recording and proper cutoff of invoices related to subawards.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
Identification of the Federal Program - Community Programs to Improve Minority Health Grant Program- Assistance Listing Number 93.137 Criteria - Per 2 CFR 200.332, Requirements for Pass-Through Entities, the City is required to monitor the subrecipients activities to ensure that the grant funds are used for authorized purposes by reviewing financial and performance reports that were required by the City. The City was also required by 2 CFR 200.332 to verify that each of their subrecipients had a single audit performed if their federal expenditures exceeded $750,000. In the Notice of Award, the Department of Health and Human Services required the City to create and provide to the Department a subrecipient monitoring plan as well as use that plan to monitor each of the City’s subrecipients. In the subrecipient monitoring plan, the City was required to perform the following steps: •Regularly communicate at least once a month with subrecipients to ensure that the project is beingcarried out as proposed and according to schedule. •Review and approve periodic technical/performance reports. •Review and approve subrecipient invoices. •Monitor general rate of expenditures and implementation of activities. •Review each subrecipient monthly through the subrecipients preparation of the City’s SubrecipientDesk Review form. •Perform an annual review for each subrecipient through the preparation of the Annual SubrecipientField Review form using the monthly desk review forms. 2 CFR 200.303, Internal Controls, requires that recipients establish and maintain effective internal control over Federal awards that provides reasonable assurance that the recipient is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition - There was a lack of subrecipient monitoring and appropriate review by the City. The City did not effectively monitor subrecipient activities to ensure the proper utilization of grant funds. There was a lack of documented evidence demonstrating the monitoring of subrecipients. The City also failed to verify whether each of their subrecipients met the threshold of $750,000 in federal expenditures and subsequently underwent a single audit. There is no documented evidence indicating that the City systematically reviewed the subrecipient expenditures to ensure compliance with this requirement. Effect - Without proper documentation and monitoring, there is an increased likelihood of financial mismanagement, misuse of funds, and noncompliance with grant terms and regulations. Additionally, the absence of adequate records impedes transparency and accountability in the use of federal funds. This deficiency also may result in undetected instances of subrecipients failing to undergo required single audits. Cause - The absence of robust monitoring procedures may stem from insufficient staff training on federal grant requirements, a lack of awareness regarding the importance of maintaining accurate records and conducting thorough monitoring of subrecipient activities, a lack of established processes for reviewing financial and performance reports, or inadequate internal controls. Additionally, there may be a lack of clear communication and accountability regarding subrecipient monitoring roles and responsibilities. Recommendation - The City should establish and enforce comprehensive subrecipient monitoring protocols. This includes developing standardized monitoring procedures, providing staff training on monitoring requirements, allocating sufficient resources for monitoring activities, and implementing mechanisms for regular review and documentation of monitoring efforts. By strengthening subrecipient monitoring practices, the City can mitigate risks, ensure compliance with grant requirements, and safeguard the effective utilization of grant funds. Views of Responsible Officials - The City agrees with the finding. The City will implement additional subrecipient monitoring procedures.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – Prevention ALN 93.959 – COVID-19 – Treatment ALN 93.959 – COVID-19 – Prevention II ALN 93.959 – COVID-19 – ARPA Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – Prevention ALN 93.959 – COVID-19 – Treatment ALN 93.959 – COVID-19 – Prevention II ALN 93.959 – COVID-19 – ARPA Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – Prevention ALN 93.959 – COVID-19 – Treatment ALN 93.959 – COVID-19 – Prevention II ALN 93.959 – COVID-19 – ARPA Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – Prevention ALN 93.959 – COVID-19 – Treatment ALN 93.959 – COVID-19 – Prevention II ALN 93.959 – COVID-19 – ARPA Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Treatment Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
Condition/Effect: The Council conducted programmatic monitoring; however, no fiscal monitoring activities were performed during the year of its sub-recipients as required by 2 CFR §200.332 (d).
Condition/Effect: The Council conducted programmatic monitoring; however, no fiscal monitoring activities were performed during the year of its sub-recipients as required by 2 CFR §200.332 (d).
Condition/Effect: The Council conducted programmatic monitoring; however, no fiscal monitoring activities were performed during the year of its sub-recipients as required by 2 CFR §200.332 (d).
Condition/Effect: The Council conducted programmatic monitoring; however, no fiscal monitoring activities were performed during the year of its sub-recipients as required by 2 CFR §200.332 (d).