Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Reference Number: 2023-002 – Significant Deficiency, Subrecipient Monitoring Criteria: Pass through entities must clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(l); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The contracts between the Council and its subrecipients did not identify the correct federal find source to its subrecipient as prescribed by 2 CFR Section 200.332. Cause: Historically, the Council has always received funding from the Department of Justice through the State of Texas. During 2023, grant award notifications indicated that the source of funding was the Department of Treasury under Assistance Listing Number 21.027, identified as Coronavirus State Fiscal Recovery Fund (Victims of Crime -SB 8). Controls in place did not allow the Council to notice that the funding source had changed and continued to inform its subrecipients that the federal funds came from the Department of Justice. Effect: The Council's subrecipients may not have timely or accurate information to determine the applicability of certain compliance requirements under the Uniform Guidance specific to the applicable Assistance Listing Number. Recommendation: Management should update policies and procedures to ensure that relevant staff are aware of funding sources and compliance requirements with respect to those sources. Management should update its sub-grant templates to ensure that required information is communicated to subrecipients. Management Response: See management’s corrective action plan.
Reference Number: 2023-002 – Significant Deficiency, Subrecipient Monitoring Criteria: Pass through entities must clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(l); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The contracts between the Council and its subrecipients did not identify the correct federal find source to its subrecipient as prescribed by 2 CFR Section 200.332. Cause: Historically, the Council has always received funding from the Department of Justice through the State of Texas. During 2023, grant award notifications indicated that the source of funding was the Department of Treasury under Assistance Listing Number 21.027, identified as Coronavirus State Fiscal Recovery Fund (Victims of Crime -SB 8). Controls in place did not allow the Council to notice that the funding source had changed and continued to inform its subrecipients that the federal funds came from the Department of Justice. Effect: The Council's subrecipients may not have timely or accurate information to determine the applicability of certain compliance requirements under the Uniform Guidance specific to the applicable Assistance Listing Number. Recommendation: Management should update policies and procedures to ensure that relevant staff are aware of funding sources and compliance requirements with respect to those sources. Management should update its sub-grant templates to ensure that required information is communicated to subrecipients. Management Response: See management’s corrective action plan.
Subrecipient Monitoring Federal Agency: U.S. Department of the Treasury Federal Program Title: Emergency Rental Assistance Program ALN: 21.023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 1505-0266 – 2021, 1505-0270 – 2021. January 6, 2022 – December 29, 2022 and May 5, 2021 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non_x0002_Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR sections 200.332 (d) through (f), all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition: TDHCA maintains a Master Planning Summary (MPS) to track all active subrecipient contracts that have expenditures in the planning phase, which are to be considered for sampling and potential selection for review. During our testing, we noted one subrecipient contract with expenditures during the fiscal year that was not included in the MPS for potential selection for a review. Questioned costs: None. Context: See “Condition.” Cause: Management is not adhering to the subrecipient monitoring procedures to ensure all active subrecipient contracts with expenditures incurred during the fiscal year are at least considered for review by being included in the MPS. Effect: Failure to complete proper monitoring over subrecipients may lead to noncompliance with grant terms and conditions. Repeat finding: No Recommendation: We recommend that TDHCA strengthen its internal controls to ensure that all subrecipients are included in the MPS and subject to review. Views of responsible officials: The Department’s Compliance Subrecipient Monitoring (CMSM) staff acknowledges that a subrecipient was erroneously not included in the Master Planning Summary. However, the Department’s procedures for risk assessment and monitoring activities for this review period remain compliant with 2 CFR section 200.303(a) as well as 2 CFR section 200.331(6)(b). Risk assessment for non-formula funded contracts is 100% risk based. Both risk assessment and subsequent monitoring functions represent a snapshot of the Department’s pass-through activities and 100% review is not required. It is the Department’s stance that this error does not materially impact the risk assessment process or the scope of this audit.
Subrecipient Monitoring Federal Agency: U.S. Department of Education Federal Program Title: Adult Education- Basic Grants to States ALN: 84.002 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: V002A200044, V002A210044, V002A220044, V002A230044 July 1, 2020 – September 30, 2021, July 1, 2021 – September 30, 2022, July 1, 2022 – September 30, 2023, July 1, 2023 – September 30, 2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non_x0002_Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR sections 200.332 (d) through (f), TWC must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition: Per review of TWC's Subrecipient Monitoring Department's (SRM) Annual Monitoring Plan, the Adult Education and Literacy (AEL) program is designed to meet the education and training needs of adults. SRM will continue to work closely with the Workforce Development Division to identify the fiscal and program areas that present the highest risk to the Agency. SRM will also conduct data validation reviews of all AEL providers, once during each five-year grant period. During our testing, we noted seven AEL subrecipients were excluded from the SRM Plan and no reviews or data validations were performed within the previous five years. Questioned costs: None. Context: See “Condition.” Cause: Management is not adhering to the subrecipient monitoring procedures to ensure all Adult Education and Literacy subrecipients have a data validation review once during each five-year granting period. Effect: Failure to complete proper monitoring over subrecipients may lead to noncompliance with grant terms and conditions. Repeat Finding: No Recommendation: We recommend that TWC strengthen its internal controls to ensure that monitoring over all subrecipients is completed. Views of responsible officials: The Texas Workforce Commission acknowledges and agrees with the finding with one observation. Follow-up review indicates that only 6 of 7 AEL subrecipients tested were not included in the risk assessment. ‘Restore Education’ was, in fact, assessed. It was SRM’s understanding from prior guidance that the types of AEL subrecipients tested as part of this audit were not applicable to SRM’s risk assessment process. We have confirmed with TWC’s AEL program staff that they should have been in scope for SRM’s annual and mid-year risk assessments.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Social Services Block Grant Block Grants for Community Mental Health Services ALN: 93.558 93.667 93.958 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2201TXTANF, and 2201TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2021 – September 30, 2022 SSBG 2301TXSOSR, 2201TXSOSR and 2101TXSOSR October 1, 2022 – September 30, 2024, October 1, 2021 – September 30, 2023, and October 1, 2020 – September 30, 2022 MHBG 1B09SM087345, 6B09SM087345-01M001, 6B09SM087345-01M002, 6B09SM087345-01M003, 1B09SM087322-01,1B09SM085994-01, 6B09SM085994-01M001, 6B09SM085994-01M002, 6B09SM085994-01M003, 1B09SM083999 -01, 6B09SM083999-01M001, 1B09SM083830-01, 6B09SM083830- 01M001 October 1, 2022 – September 30, 2024, October 17, 2022 – October 16, 2024, October 1, 2021 – September 30, 2023, March 15, 2021 – March 14, 2024, March 15, 2021 – March 14, 2023, and October 1, 2020 – September 30, 2022 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain 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: Subrecipient’s unique entity identifier (UEI) Federal award identification number (FAIN) Federal award date of award to the recipient by the federal agency Assistance listings number and title Indirect cost rate for the federal award (including if the de minimis rate is charged) Condition: Audit procedures included a review of a sample of subrecipient contracts for required information with the following results noted: TANF – For a sample of 17, the contracts did not include: UEI (one sample) FAIN (four samples) Federal award date (four samples) Assistance listings numbers and title (four samples) Indirect cost rate, including if the de minimis rate is charged (four samples) SSBG – For 11 of 19 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. MHBG – For 7 of 8 samples, the contract did not include neither the FAIN nor the federal award date of award to the recipient by the federal agency. Questioned costs: None. Context: See “Condition.” Cause: Current internal controls in place to ensure a review of subaward agreements is taking place to verify that all required elements are included per 2 CFR 200 §200.332 are not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: Temporary Assistance for Needy Families (TANF) - HHSC concurs with the finding. Social Services Block Grants (SSBG)/ Mental Health Block Grants (MHBG) - HHSC concurs with the finding.
Reference Number: 2023-002 – Significant Deficiency, Subrecipient Monitoring Criteria: Pass through entities must clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(l); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The contracts between the Council and its subrecipients did not identify the correct federal find source to its subrecipient as prescribed by 2 CFR Section 200.332. Cause: Historically, the Council has always received funding from the Department of Justice through the State of Texas. During 2023, grant award notifications indicated that the source of funding was the Department of Treasury under Assistance Listing Number 21.027, identified as Coronavirus State Fiscal Recovery Fund (Victims of Crime -SB 8). Controls in place did not allow the Council to notice that the funding source had changed and continued to inform its subrecipients that the federal funds came from the Department of Justice. Effect: The Council's subrecipients may not have timely or accurate information to determine the applicability of certain compliance requirements under the Uniform Guidance specific to the applicable Assistance Listing Number. Recommendation: Management should update policies and procedures to ensure that relevant staff are aware of funding sources and compliance requirements with respect to those sources. Management should update its sub-grant templates to ensure that required information is communicated to subrecipients. Management Response: See management’s corrective action plan.
Reference Number: 2023-002 – Significant Deficiency, Subrecipient Monitoring Criteria: Pass through entities must clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(l); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition: The contracts between the Council and its subrecipients did not identify the correct federal find source to its subrecipient as prescribed by 2 CFR Section 200.332. Cause: Historically, the Council has always received funding from the Department of Justice through the State of Texas. During 2023, grant award notifications indicated that the source of funding was the Department of Treasury under Assistance Listing Number 21.027, identified as Coronavirus State Fiscal Recovery Fund (Victims of Crime -SB 8). Controls in place did not allow the Council to notice that the funding source had changed and continued to inform its subrecipients that the federal funds came from the Department of Justice. Effect: The Council's subrecipients may not have timely or accurate information to determine the applicability of certain compliance requirements under the Uniform Guidance specific to the applicable Assistance Listing Number. Recommendation: Management should update policies and procedures to ensure that relevant staff are aware of funding sources and compliance requirements with respect to those sources. Management should update its sub-grant templates to ensure that required information is communicated to subrecipients. Management Response: See management’s corrective action plan.
Department of Treasury Program Name: Emergency Rental Assistance Program Federal Assistance Listing Number: 21.023 Nonmaterial Noncompliance, Material Weakness – Subrecipient Monitoring Finding 2023-001 Criteria: An effective system of internal control contemplates that management properly review and assess the subrecipient through monitoring procedures and document the results of the procedures performed. This includes ensuring the subrecipient is following all direct and material compliance requirements applicable to each federal program. Condition: It was discovered while testing the program that the City did not monitor the activity of its subrecipient for the Emergency Rental Assistance Program and did not have a plan to complete monitoring for fiscal year 2023. However, the City did properly obtain and review the subrecipients single audit report for fiscal year 2022. Effect: The subrecipient could provide federal funds to ineligible individuals resulting in questioned costs that could go undetected by the City. Questioned Costs: No questioned costs were identified as a result of our procedures. Cause: The City has an overall policy on monitoring subrecipients but individual departments do not have formal policies or guidelines in place for specific monitoring plans on each of their subrecipients/programs. Recommendation: We recommend the City require, as part of their subrecipient policy, that departments have written monitoring plans for each program that utilizes subrecipients that includes, but is not limited to, an annual risk assessment of the subrecipient, timeline for monitoring (monthly, quarterly, semi-annually, annually) to take place and how it will communicate and follow up with any findings identified from the monitoring. Furthermore, management should further utilize 2 CFR 200.332 to ensure all monitoring requirements are met. Views of responsible officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the corrective action plan. Corrective Action Plan: See Corrective Action Plan prepared by the City.
Department of Treasury Program Name: Emergency Rental Assistance Program Federal Assistance Listing Number: 21.023 Nonmaterial Noncompliance, Material Weakness – Subrecipient Monitoring Finding 2023-001 Criteria: An effective system of internal control contemplates that management properly review and assess the subrecipient through monitoring procedures and document the results of the procedures performed. This includes ensuring the subrecipient is following all direct and material compliance requirements applicable to each federal program. Condition: It was discovered while testing the program that the City did not monitor the activity of its subrecipient for the Emergency Rental Assistance Program and did not have a plan to complete monitoring for fiscal year 2023. However, the City did properly obtain and review the subrecipients single audit report for fiscal year 2022. Effect: The subrecipient could provide federal funds to ineligible individuals resulting in questioned costs that could go undetected by the City. Questioned Costs: No questioned costs were identified as a result of our procedures. Cause: The City has an overall policy on monitoring subrecipients but individual departments do not have formal policies or guidelines in place for specific monitoring plans on each of their subrecipients/programs. Recommendation: We recommend the City require, as part of their subrecipient policy, that departments have written monitoring plans for each program that utilizes subrecipients that includes, but is not limited to, an annual risk assessment of the subrecipient, timeline for monitoring (monthly, quarterly, semi-annually, annually) to take place and how it will communicate and follow up with any findings identified from the monitoring. Furthermore, management should further utilize 2 CFR 200.332 to ensure all monitoring requirements are met. Views of responsible officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the corrective action plan. Corrective Action Plan: See Corrective Action Plan prepared by the City.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Condition While the University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports, subsequent review of Uniform Guidance reports for monitoring purposes is not consistently completed. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment, or no less frequently than an annual basis per University policy, however, for 4 out of 25 subaward selections, the subawards were not amended within a year. As such, over a year passed since a Uniform Guidance report was reviewed for these subrecipients for monitoring purposes. Additionally, given the risk assessments are used to cover certain post-award subrecipient monitoring requirements, we noted the following: • 4 out of 25 selections did not have clear documentation as to which Uniform Guidance report had been specifically reviewed • 3 out of 25 subrecipients had findings/deficiencies in their Uniform Guidance reports and there was no documentation for how the University concluded these were not relevant to their subawards • 1 out of 5 subrecipients without Uniform Guidance reports did not have notations on alternative support that was reviewed in lieu of Uniform Guidance reports, as required by University policy. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause Review of Uniform Guidance reports for post-award monitoring purposes is dependent upon a subaward amendment being executed. If an annual amendment is not executed, there is a gap in the monitoring process as the latest Uniform Guidance reports did not get reviewed. While the University expected all subrecipients to have a subaward amendment processed within a year, the testing noted above identified instances where no amendment was processed, and as such, a Uniform Guidance report was not reviewed within that period of time. Additionally, in regard to the completeness of documentation within the risk assessments, while individuals executing the subaward agreements are required to review the risk assessment form in conjunction with the agreement, there is no formal secondary review required to be evidenced and as such, certain elements were overlooked. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University review their policies and procedures specific to reviewing Uniform Guidance reports of subrecipients for post-award monitoring purposes to ensure all subrecipient reports are reviewed annually. Additionally, we recommend a formal secondary sign-off be included on the risk assessment form to ensure completeness and agreement with conclusions reached. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings