2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements Governor’s Office of Planning and Budget (Finding Type: Significant Deficiency and Reportable Noncompliance) Federal Agency: Department of the Treasury Assistance Listing Number and Title: 21.027 Coronavirus State & Local Fiscal Recovery Funds Federal Award Number: N/A Questioned Costs: $0 Pass-through Entity: N/A Prior Year Single Audit Report Finding Number: 2022-026 GOPB, the prime recipient for the State and Local Fiscal Recovery Funds (SLFRF), and state agencies, including the Governor’s Office of Economic Development (GOEO), Department of Natural Resources (DNR), and Department of Environmental Quality (DEQ), did not adequately fulfill their subrecipient monitoring responsibilities for 53 agreements passing through nearly $105 million during State fiscal year 2023 as follows: Communication of Key Federal Grant Information, Risk Evaluation, and Compliance Monitoring GOEO, DNR, and DEQ did not implement adequate policies and procedures, properly communicate key federal grant information as required by 2 CRF 200.332(a), evaluate subrecipient risk, and monitor subrecipients for compliance as required by 2 CRF 200.332(b) and (d). From a sample of nine subrecipients, we noted the following: (see pdf for table) Subrecipient Single Audit Report Reviews GOPB did not review subrecipient Single Audit reports and findings for 2 of 3 sampled awards to assess whether the subrecipients spent the funds appropriately. GOPB did not have adequate controls to ensure its subrecipients’ Single Audit reports were monitored according to federal requirements. Uniform Guidance (2 CFR 200.332(d)(2)) requires a review of subrecipient Single Audit reports when they become available and a follow-up to ensure that any findings related to the applicable program are addressed. GOPB implemented a process to review Single Audit reports, but the control in place failed to identify all subrecipients that had Single Audit reports available for review. The errors noted above were a result of the agencies, including GOPB, not fully understanding the nature of the funds they received, the extent of compliance requirements, and the nature of the subaward agreement relationships. Failure to establish internal controls, adequately communicate key federal program information to subrecipients, and perform risk evaluation and monitoring procedures may result in the subrecipient’s noncompliance with federal fund requirements and potential misuse of federal funds. Recommendations: We recommend that GOPB work with other state entities like GOEO, DNR, and DEQ ensure an adequate understanding of the subrecipient requirements required by 2 CFR 200.332, including: 1. Establish appropriate internal controls and written policies and procedures to properly identify subrecipients and ensure compliance with subrecipient monitoring requirements, 2. Communicate all required federal award information to sub-recipients, 3. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and 4. Monitor subrecipients according to their assessed risk. GOPB’s Response: GOPB agrees with this finding. This is a repeat finding from the 2022 single audit because there was insufficient time to implement the previous corrective action plan between the release of the audit and end of fiscal year 2023. GOPB has taken proactive measures to support state agencies in meeting their monitoring obligations after concerns were identified during the 2022 single audit. On May 15, 2023, GOPB distributed an email communication containing the ARPA Reference Guide to all state agencies responsible for administering ARPA SLFRF funds. This guide serves as a detailed resource outlining essential compliance documents necessary for effective implementation and monitoring of SLFRF programs. The ARPA Reference Guide includes a range of compliance documents, including the State Agency Checklist, SLFRF Administrative and Indirect Costs Eligibility, Single Audit Compliance guidelines, Internal Controls Reference Guide, Risk Assessment Checklist, Agreement Checklist, and Subrecipient, Beneficiary, and Contractor Checklist. On May 31 and June 6, 2023, GOPB provided federal funds compliance training to agency financial management staff to cover various topics crucial to SLFRF oversight, including the ARPA Reference Guide, Unique Entity ID (UEI), FINET ARPA Coding, Agency Checklist, and Agency Reviews. As outlined in the Final Rule FAQ 13.15, projects categorized under Expenditure Category 6, also known as “Revenue Replacement,” are exempt from some provisions in uniform guidance. Some of the projects sampled during the audit, including a portion of the projects managed by the Governor’s Office of Economic Opportunity (GOEO) and GOPB, fall under the revenue replacement category.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect: The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the Healthy Marriage Promotion and Responsible Fatherhood Grants. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the Healthy Marriage Promotion and Responsible Fatherhood Grants. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the Healthy Marriage Promotion and Responsible Fatherhood Grants. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the Healthy Marriage Promotion and Responsible Fatherhood Grants. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.
Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Effect: The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Federal program: All federal awards provided to subrecipients. FY/Federal Award ID#: FY2023/All federal awards provided to subrecipients. Federal agency: All federal awards provided by subrecipients. Pass thru entity: All federal awards provided by subrecipients. Criteria: Per 24 CFR 574.500 -- Responsibility for grant administration: (a)General. Grantees are responsible for ensuring that grants are administrated in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements. (b)Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to: (1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations; (2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program; (3) Assure the adequate provision of supportive services to the participants in the program; and (4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for the program monitoring and elevation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 - Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(F) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipients Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. Condition: The foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive risk-based/subrecipient monitoring policies and procedures. Questioned Costs: None noted. Cause: Staff were not aware of requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements. Recommendation: The Foundation provide written policies and procedures for the project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed. View of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundations Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.
Reference Number: 2023-010 Prior Year Finding: 2022-021 Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/1/2021 – 12/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance – 2 CFR §200.332(a) - Requirements for Pass-Through Entities, states in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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. Control – 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-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). Condition: Required federal award information was omitted from subaward agreements issued using program funds. Context: The Agency of Administration (Agency) has oversight responsibility for Coronavirus State and Local Fiscal Recovery Funds expenditures and reporting for the State of Vermont (the State). Multiple agencies and departments within the State incur costs and issue subawards with program funding. Twenty-nine subrecipients were selected for testing, consisting of thirty-seven individual subawards issued by multiple agencies and departments. For 10 of 37 subaward agreements selected for testing, the Department of Public Service (Department) omitted the following required Federal information: • Federal Award Identification Number (FAIN) • Federal Award Date Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: The Department did not establish effective internal controls and procedures over subrecipient monitoring. It was unable to ensure that it provided all required information to its subrecipients upon award issuance. The Agency’s oversight of the program did not detect the error. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: Undetermined. Recommendation: We recommend the Agency work with the Department to review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards. We further recommend that the Agency review its oversight procedures and controls to ensure that all State agencies and departments that issue subawards under the program are in compliance with federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Award Number and Year: VT2016-007-02 (9/23/2016 – 6/20/2023), VT-2017-007-01 (8/3/2017 – 6/21/2023), VT-2019-006-01 (9/20/2017 – 9/30/2022), VT-2020-005-00 (5/26/2020 – 9/30/2022), VT-2020-011-00 (9/9/2020 – 9/30/2023), VT-2020-012-00 (9/18/2020 – 9/30/2023), VT-2021-014-01 (9/20/2021 – 9/30/2023), VT-2022-001-02 (5/12/2022 – 6/30/2028) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. Control – 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-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). Condition: The Vermont Agency of Transportation (VTrans) omitted required federal award information from subawards it issued in the program and did not adequately monitor subrecipients. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Seven subawards were selected for testing and the following exceptions were noted: • For seven of seven subawards selected for testing, the FAIN and federal award date were not included on the subaward agreement. • For three of seven subawards selected for testing, the last on-site subrecipient monitoring visits were performed in FY 2020 and the next on-site monitoring is not scheduled to take place until FY 2024. Per the VTrans subrecipient monitoring plan, on-site monitoring must be performed no less than every three years. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required federal information. Although VTrans subsequently modified its subaward issuance process, controls in effect during the audit period were not sufficient to ensure that subawards included all required information. Procedures and internal controls were also not sufficient to ensure that timely on-site monitoring visits were performed in accordance with its monitoring plan. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Failure to conduct adequate subrecipient monitoring may result in a failure of VTrans to detect that subawards were used for unauthorized purposes, were managed in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. There is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by VTrans personnel on a timely basis. Questioned costs: Undetermined. Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Award Number and Year: VT2016-007-02 (9/23/2016 – 6/20/2023), VT-2017-007-01 (8/3/2017 – 6/21/2023), VT-2019-006-01 (9/20/2017 – 9/30/2022), VT-2020-005-00 (5/26/2020 – 9/30/2022), VT-2020-011-00 (9/9/2020 – 9/30/2023), VT-2020-012-00 (9/18/2020 – 9/30/2023), VT-2021-014-01 (9/20/2021 – 9/30/2023), VT-2022-001-02 (5/12/2022 – 6/30/2028) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. Control – 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-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). Condition: The Vermont Agency of Transportation (VTrans) omitted required federal award information from subawards it issued in the program and did not adequately monitor subrecipients. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Seven subawards were selected for testing and the following exceptions were noted: • For seven of seven subawards selected for testing, the FAIN and federal award date were not included on the subaward agreement. • For three of seven subawards selected for testing, the last on-site subrecipient monitoring visits were performed in FY 2020 and the next on-site monitoring is not scheduled to take place until FY 2024. Per the VTrans subrecipient monitoring plan, on-site monitoring must be performed no less than every three years. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required federal information. Although VTrans subsequently modified its subaward issuance process, controls in effect during the audit period were not sufficient to ensure that subawards included all required information. Procedures and internal controls were also not sufficient to ensure that timely on-site monitoring visits were performed in accordance with its monitoring plan. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Failure to conduct adequate subrecipient monitoring may result in a failure of VTrans to detect that subawards were used for unauthorized purposes, were managed in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. There is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by VTrans personnel on a timely basis. Questioned costs: Undetermined. Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-014 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Special Education Cluster, COVID-19 – Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Award Number and Year: H027A210098 (7/1/2021 – 9/30/2022), H173A200106 (7/1/2020 – 9/30/2022), H173A210106 (7/1/2021 – 9/30/2022), H027A220098 (7/1/2022 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (2) (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Context: For 2 of 8 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-014 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Special Education Cluster, COVID-19 – Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Award Number and Year: H027A210098 (7/1/2021 – 9/30/2022), H173A200106 (7/1/2020 – 9/30/2022), H173A210106 (7/1/2021 – 9/30/2022), H027A220098 (7/1/2022 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (2) (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Context: For 2 of 8 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-014 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Special Education Cluster, COVID-19 – Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Award Number and Year: H027A210098 (7/1/2021 – 9/30/2022), H173A200106 (7/1/2020 – 9/30/2022), H173A210106 (7/1/2021 – 9/30/2022), H027A220098 (7/1/2022 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (2) (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Context: For 2 of 8 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-014 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Special Education Cluster, COVID-19 – Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Award Number and Year: H027A210098 (7/1/2021 – 9/30/2022), H173A200106 (7/1/2020 – 9/30/2022), H173A210106 (7/1/2021 – 9/30/2022), H027A220098 (7/1/2022 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (2) (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Context: For 2 of 8 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2023-017 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) Assistance Listing Number: 84.367 Award Number and Year: S367A210043 (7/1/2021 – 9/30/2022), S367A220043 (7/1/2022 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (c) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (3) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Context: Eight subawards were selected for testing and the following exceptions were noted: • For 1 of 8 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) • For 3 of 8 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332, the following requirements are imposed on pass-through entities: (d) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes 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: (4) (ii) Subrecipient's unique entity identifier; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient. Control – 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-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). Condition: The Vermont Agency of Education (Agency) omitted required information from subawards it issued for the program. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Context: Twenty-seven subawards were selected for testing and the following exceptions were noted: • For 4 of 27 subawards selected for testing, the subrecipient’s unique entity identifier was not included on the subaward agreement. • For 8 of 27 subawards selected for testing, the amount of federal funds obligated by this action was not included on the subaward agreement. Cause: Procedures and internal controls were not sufficient to ensure that subawards included all required information. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: None noted. Recommendation: The Agency should review and enhance internal controls and procedures to ensure that all required federal award information is included in subaward agreements. Views of responsible officials: Management agrees with the finding.
2023-013 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: None AL Numbers and Titles: 10.565 – Commodity Supplemental Food Program 10.568 – Emergency Food Assistance Program (Administrative Costs) 10.568 – COVID-19 – Emergency Food Assistance Program (Administrative Costs) 10.569 – Emergency Food Assistance Program (Food Commodities) Federal Award Numbers: 235GA802Y8005 (Year: 2023), 225GA802Y8005 (Year: 2022), 235GA820Y8105 (Year: 2023), 225GA413Q2204 (Year: 2022), 225GA820Y8105 (Year: 2022), 215GA820Y8105 (Year: 2021), 195GA820Y8105 (Year: 2019), 225GA823P1103 (Year: 2022) Questioned Costs: None Identified Description: The Department of Human Services should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Food Distribution Cluster is comprised of the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP) and is intended to strengthen the nutrition safety net through the provisions of the U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. CSFP provides a package of USDA Foods to low-income elderly people at least 60 years of age. CSFP food packages are not intended to provide a complete diet but rather provide the nutrients that are typically lacking in the diets of the target population. TEFAP provides USDA Foods to low-income households for home consumption or for use in prepared meals at emergency feeding sites for low-income persons. USDA Foods associated with the Food Distribution Cluster programs are provided to the Department of Human Services (DHS) for allocation to eligible subrecipients. These subrecipients are responsible for the determination of individual eligibility and who receives benefits. Because the DHS subgrants donated foods to various entities, the DHS must perform certain monitoring activities related to these subrecipients. These monitoring activities include a review of individual eligibility determinations completed by subrecipients to ensure categorical and income eligibility requirements are met before distributing food items. Criteria: As a recipient of federal awards, the DHS is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that “All pass-through entities must… (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved…” Additionally, pursuant to Title 7 CFR Section 247.34(a), under the CSFP, “the State agency must establish a management review system to ensure that local agencies, subdistributing agencies, and other agencies conducting program activities meet program requirements and objectives. As part of the system, the State agency must perform an on-site review of all local agencies, and of all storage facilities utilized by local agencies, at least once every two years. As part of the on-site review, the State agency must evaluate all aspects of program administration, including certification procedures, nutrition education, civil rights compliance, food storage practices, inventory controls, and financial management systems. In addition to conducting on-site reviews, the State agency must evaluate program administration on an ongoing basis by reviewing financial reports, audit reports, food orders, inventory reports, and other relevant information.” Furthermore, pursuant to Title 7 CFR Section 251.10(e), under the TEFAP, “(1) Each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements… (2)… the State agency monitoring system must include: (i) An annual review of at least 25 percent of all eligible recipient agencies which have signed an agreement with the State agency… provided that each such agency must be reviewed no less frequently than once every four years; and (ii) An annual review of one-tenth or 20, whichever is fewer, of all eligible recipient agencies which receive TEFAP commodities and/or administrative funds pursuant to an agreement with another eligible recipient agency. Reviews must be conducted, to the maximum extent feasible, simultaneously with actual distribution of commodities and/or meal service, and eligibility determinations, if applicable. State agencies must develop a system for selecting eligible recipient agencies for review that ensures deficiencies in program administration are detected and resolved in an effective and efficient manner. (3) Each review must encompass, as applicable, eligibility determinations, food ordering procedures, storage and warehousing practices, inventory controls, approval of distribution sites, reporting and recordkeeping requirements, and civil rights. Condition: All subrecipients associated with the Food Distribution Cluster were selected for testing. Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: • Auditors reviewed documentation to determine if appropriate monitoring was conducted over CSFP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one of the two CSFP subrecipients tested. • Auditors also reviewed documentation to determine if appropriate monitoring was conducted over TEFAP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for any of the seven TEFAP subrecipients tested and 13 of the required 20 TEFAP sub-distributing subrecipients. • As a result of not completing the required subrecipient monitoring reviews, the DHS also failed to review the subrecipients’ eligibility determinations for individual beneficiaries. Cause: Through discussion with management, high staff turnover, including the lack of a TEFAP and CSFP Coordinator, caused delays in conducting the required monitoring reviews. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal donated foods being distributed to ineligible individuals, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the DHS: • Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements and ensure individual eligibility determinations are being reviewed; • Develop an annual monitoring schedule for reviews of TEFAP and CSFP subrecipients to ensure compliance with monitoring of the required number of Eligible Recipient Agencies (ERAs); and • Maintain a tracking log that includes a listing of all TEFAP and CSFP subrecipients, date the monitoring review was performed, who completed the monitoring review, and if there were any deficiencies noted during the review. Views of Responsible Officials: The Georgia Department of Human Services (DHS) concurs with the finding.
2023-013 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: None AL Numbers and Titles: 10.565 – Commodity Supplemental Food Program 10.568 – Emergency Food Assistance Program (Administrative Costs) 10.568 – COVID-19 – Emergency Food Assistance Program (Administrative Costs) 10.569 – Emergency Food Assistance Program (Food Commodities) Federal Award Numbers: 235GA802Y8005 (Year: 2023), 225GA802Y8005 (Year: 2022), 235GA820Y8105 (Year: 2023), 225GA413Q2204 (Year: 2022), 225GA820Y8105 (Year: 2022), 215GA820Y8105 (Year: 2021), 195GA820Y8105 (Year: 2019), 225GA823P1103 (Year: 2022) Questioned Costs: None Identified Description: The Department of Human Services should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Food Distribution Cluster is comprised of the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP) and is intended to strengthen the nutrition safety net through the provisions of the U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. CSFP provides a package of USDA Foods to low-income elderly people at least 60 years of age. CSFP food packages are not intended to provide a complete diet but rather provide the nutrients that are typically lacking in the diets of the target population. TEFAP provides USDA Foods to low-income households for home consumption or for use in prepared meals at emergency feeding sites for low-income persons. USDA Foods associated with the Food Distribution Cluster programs are provided to the Department of Human Services (DHS) for allocation to eligible subrecipients. These subrecipients are responsible for the determination of individual eligibility and who receives benefits. Because the DHS subgrants donated foods to various entities, the DHS must perform certain monitoring activities related to these subrecipients. These monitoring activities include a review of individual eligibility determinations completed by subrecipients to ensure categorical and income eligibility requirements are met before distributing food items. Criteria: As a recipient of federal awards, the DHS is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that “All pass-through entities must… (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved…” Additionally, pursuant to Title 7 CFR Section 247.34(a), under the CSFP, “the State agency must establish a management review system to ensure that local agencies, subdistributing agencies, and other agencies conducting program activities meet program requirements and objectives. As part of the system, the State agency must perform an on-site review of all local agencies, and of all storage facilities utilized by local agencies, at least once every two years. As part of the on-site review, the State agency must evaluate all aspects of program administration, including certification procedures, nutrition education, civil rights compliance, food storage practices, inventory controls, and financial management systems. In addition to conducting on-site reviews, the State agency must evaluate program administration on an ongoing basis by reviewing financial reports, audit reports, food orders, inventory reports, and other relevant information.” Furthermore, pursuant to Title 7 CFR Section 251.10(e), under the TEFAP, “(1) Each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements… (2)… the State agency monitoring system must include: (i) An annual review of at least 25 percent of all eligible recipient agencies which have signed an agreement with the State agency… provided that each such agency must be reviewed no less frequently than once every four years; and (ii) An annual review of one-tenth or 20, whichever is fewer, of all eligible recipient agencies which receive TEFAP commodities and/or administrative funds pursuant to an agreement with another eligible recipient agency. Reviews must be conducted, to the maximum extent feasible, simultaneously with actual distribution of commodities and/or meal service, and eligibility determinations, if applicable. State agencies must develop a system for selecting eligible recipient agencies for review that ensures deficiencies in program administration are detected and resolved in an effective and efficient manner. (3) Each review must encompass, as applicable, eligibility determinations, food ordering procedures, storage and warehousing practices, inventory controls, approval of distribution sites, reporting and recordkeeping requirements, and civil rights. Condition: All subrecipients associated with the Food Distribution Cluster were selected for testing. Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: • Auditors reviewed documentation to determine if appropriate monitoring was conducted over CSFP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one of the two CSFP subrecipients tested. • Auditors also reviewed documentation to determine if appropriate monitoring was conducted over TEFAP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for any of the seven TEFAP subrecipients tested and 13 of the required 20 TEFAP sub-distributing subrecipients. • As a result of not completing the required subrecipient monitoring reviews, the DHS also failed to review the subrecipients’ eligibility determinations for individual beneficiaries. Cause: Through discussion with management, high staff turnover, including the lack of a TEFAP and CSFP Coordinator, caused delays in conducting the required monitoring reviews. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal donated foods being distributed to ineligible individuals, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the DHS: • Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements and ensure individual eligibility determinations are being reviewed; • Develop an annual monitoring schedule for reviews of TEFAP and CSFP subrecipients to ensure compliance with monitoring of the required number of Eligible Recipient Agencies (ERAs); and • Maintain a tracking log that includes a listing of all TEFAP and CSFP subrecipients, date the monitoring review was performed, who completed the monitoring review, and if there were any deficiencies noted during the review. Views of Responsible Officials: The Georgia Department of Human Services (DHS) concurs with the finding.
2023-013 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: None AL Numbers and Titles: 10.565 – Commodity Supplemental Food Program 10.568 – Emergency Food Assistance Program (Administrative Costs) 10.568 – COVID-19 – Emergency Food Assistance Program (Administrative Costs) 10.569 – Emergency Food Assistance Program (Food Commodities) Federal Award Numbers: 235GA802Y8005 (Year: 2023), 225GA802Y8005 (Year: 2022), 235GA820Y8105 (Year: 2023), 225GA413Q2204 (Year: 2022), 225GA820Y8105 (Year: 2022), 215GA820Y8105 (Year: 2021), 195GA820Y8105 (Year: 2019), 225GA823P1103 (Year: 2022) Questioned Costs: None Identified Description: The Department of Human Services should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Food Distribution Cluster is comprised of the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP) and is intended to strengthen the nutrition safety net through the provisions of the U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. CSFP provides a package of USDA Foods to low-income elderly people at least 60 years of age. CSFP food packages are not intended to provide a complete diet but rather provide the nutrients that are typically lacking in the diets of the target population. TEFAP provides USDA Foods to low-income households for home consumption or for use in prepared meals at emergency feeding sites for low-income persons. USDA Foods associated with the Food Distribution Cluster programs are provided to the Department of Human Services (DHS) for allocation to eligible subrecipients. These subrecipients are responsible for the determination of individual eligibility and who receives benefits. Because the DHS subgrants donated foods to various entities, the DHS must perform certain monitoring activities related to these subrecipients. These monitoring activities include a review of individual eligibility determinations completed by subrecipients to ensure categorical and income eligibility requirements are met before distributing food items. Criteria: As a recipient of federal awards, the DHS is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that “All pass-through entities must… (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved…” Additionally, pursuant to Title 7 CFR Section 247.34(a), under the CSFP, “the State agency must establish a management review system to ensure that local agencies, subdistributing agencies, and other agencies conducting program activities meet program requirements and objectives. As part of the system, the State agency must perform an on-site review of all local agencies, and of all storage facilities utilized by local agencies, at least once every two years. As part of the on-site review, the State agency must evaluate all aspects of program administration, including certification procedures, nutrition education, civil rights compliance, food storage practices, inventory controls, and financial management systems. In addition to conducting on-site reviews, the State agency must evaluate program administration on an ongoing basis by reviewing financial reports, audit reports, food orders, inventory reports, and other relevant information.” Furthermore, pursuant to Title 7 CFR Section 251.10(e), under the TEFAP, “(1) Each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements… (2)… the State agency monitoring system must include: (i) An annual review of at least 25 percent of all eligible recipient agencies which have signed an agreement with the State agency… provided that each such agency must be reviewed no less frequently than once every four years; and (ii) An annual review of one-tenth or 20, whichever is fewer, of all eligible recipient agencies which receive TEFAP commodities and/or administrative funds pursuant to an agreement with another eligible recipient agency. Reviews must be conducted, to the maximum extent feasible, simultaneously with actual distribution of commodities and/or meal service, and eligibility determinations, if applicable. State agencies must develop a system for selecting eligible recipient agencies for review that ensures deficiencies in program administration are detected and resolved in an effective and efficient manner. (3) Each review must encompass, as applicable, eligibility determinations, food ordering procedures, storage and warehousing practices, inventory controls, approval of distribution sites, reporting and recordkeeping requirements, and civil rights. Condition: All subrecipients associated with the Food Distribution Cluster were selected for testing. Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: • Auditors reviewed documentation to determine if appropriate monitoring was conducted over CSFP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one of the two CSFP subrecipients tested. • Auditors also reviewed documentation to determine if appropriate monitoring was conducted over TEFAP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for any of the seven TEFAP subrecipients tested and 13 of the required 20 TEFAP sub-distributing subrecipients. • As a result of not completing the required subrecipient monitoring reviews, the DHS also failed to review the subrecipients’ eligibility determinations for individual beneficiaries. Cause: Through discussion with management, high staff turnover, including the lack of a TEFAP and CSFP Coordinator, caused delays in conducting the required monitoring reviews. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal donated foods being distributed to ineligible individuals, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the DHS: • Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements and ensure individual eligibility determinations are being reviewed; • Develop an annual monitoring schedule for reviews of TEFAP and CSFP subrecipients to ensure compliance with monitoring of the required number of Eligible Recipient Agencies (ERAs); and • Maintain a tracking log that includes a listing of all TEFAP and CSFP subrecipients, date the monitoring review was performed, who completed the monitoring review, and if there were any deficiencies noted during the review. Views of Responsible Officials: The Georgia Department of Human Services (DHS) concurs with the finding.
2023-013 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: None AL Numbers and Titles: 10.565 – Commodity Supplemental Food Program 10.568 – Emergency Food Assistance Program (Administrative Costs) 10.568 – COVID-19 – Emergency Food Assistance Program (Administrative Costs) 10.569 – Emergency Food Assistance Program (Food Commodities) Federal Award Numbers: 235GA802Y8005 (Year: 2023), 225GA802Y8005 (Year: 2022), 235GA820Y8105 (Year: 2023), 225GA413Q2204 (Year: 2022), 225GA820Y8105 (Year: 2022), 215GA820Y8105 (Year: 2021), 195GA820Y8105 (Year: 2019), 225GA823P1103 (Year: 2022) Questioned Costs: None Identified Description: The Department of Human Services should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Food Distribution Cluster is comprised of the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP) and is intended to strengthen the nutrition safety net through the provisions of the U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. CSFP provides a package of USDA Foods to low-income elderly people at least 60 years of age. CSFP food packages are not intended to provide a complete diet but rather provide the nutrients that are typically lacking in the diets of the target population. TEFAP provides USDA Foods to low-income households for home consumption or for use in prepared meals at emergency feeding sites for low-income persons. USDA Foods associated with the Food Distribution Cluster programs are provided to the Department of Human Services (DHS) for allocation to eligible subrecipients. These subrecipients are responsible for the determination of individual eligibility and who receives benefits. Because the DHS subgrants donated foods to various entities, the DHS must perform certain monitoring activities related to these subrecipients. These monitoring activities include a review of individual eligibility determinations completed by subrecipients to ensure categorical and income eligibility requirements are met before distributing food items. Criteria: As a recipient of federal awards, the DHS is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that “All pass-through entities must… (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved…” Additionally, pursuant to Title 7 CFR Section 247.34(a), under the CSFP, “the State agency must establish a management review system to ensure that local agencies, subdistributing agencies, and other agencies conducting program activities meet program requirements and objectives. As part of the system, the State agency must perform an on-site review of all local agencies, and of all storage facilities utilized by local agencies, at least once every two years. As part of the on-site review, the State agency must evaluate all aspects of program administration, including certification procedures, nutrition education, civil rights compliance, food storage practices, inventory controls, and financial management systems. In addition to conducting on-site reviews, the State agency must evaluate program administration on an ongoing basis by reviewing financial reports, audit reports, food orders, inventory reports, and other relevant information.” Furthermore, pursuant to Title 7 CFR Section 251.10(e), under the TEFAP, “(1) Each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements… (2)… the State agency monitoring system must include: (i) An annual review of at least 25 percent of all eligible recipient agencies which have signed an agreement with the State agency… provided that each such agency must be reviewed no less frequently than once every four years; and (ii) An annual review of one-tenth or 20, whichever is fewer, of all eligible recipient agencies which receive TEFAP commodities and/or administrative funds pursuant to an agreement with another eligible recipient agency. Reviews must be conducted, to the maximum extent feasible, simultaneously with actual distribution of commodities and/or meal service, and eligibility determinations, if applicable. State agencies must develop a system for selecting eligible recipient agencies for review that ensures deficiencies in program administration are detected and resolved in an effective and efficient manner. (3) Each review must encompass, as applicable, eligibility determinations, food ordering procedures, storage and warehousing practices, inventory controls, approval of distribution sites, reporting and recordkeeping requirements, and civil rights. Condition: All subrecipients associated with the Food Distribution Cluster were selected for testing. Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: • Auditors reviewed documentation to determine if appropriate monitoring was conducted over CSFP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one of the two CSFP subrecipients tested. • Auditors also reviewed documentation to determine if appropriate monitoring was conducted over TEFAP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for any of the seven TEFAP subrecipients tested and 13 of the required 20 TEFAP sub-distributing subrecipients. • As a result of not completing the required subrecipient monitoring reviews, the DHS also failed to review the subrecipients’ eligibility determinations for individual beneficiaries. Cause: Through discussion with management, high staff turnover, including the lack of a TEFAP and CSFP Coordinator, caused delays in conducting the required monitoring reviews. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal donated foods being distributed to ineligible individuals, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the DHS: • Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements and ensure individual eligibility determinations are being reviewed; • Develop an annual monitoring schedule for reviews of TEFAP and CSFP subrecipients to ensure compliance with monitoring of the required number of Eligible Recipient Agencies (ERAs); and • Maintain a tracking log that includes a listing of all TEFAP and CSFP subrecipients, date the monitoring review was performed, who completed the monitoring review, and if there were any deficiencies noted during the review. Views of Responsible Officials: The Georgia Department of Human Services (DHS) concurs with the finding.
2023-013 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: None AL Numbers and Titles: 10.565 – Commodity Supplemental Food Program 10.568 – Emergency Food Assistance Program (Administrative Costs) 10.568 – COVID-19 – Emergency Food Assistance Program (Administrative Costs) 10.569 – Emergency Food Assistance Program (Food Commodities) Federal Award Numbers: 235GA802Y8005 (Year: 2023), 225GA802Y8005 (Year: 2022), 235GA820Y8105 (Year: 2023), 225GA413Q2204 (Year: 2022), 225GA820Y8105 (Year: 2022), 215GA820Y8105 (Year: 2021), 195GA820Y8105 (Year: 2019), 225GA823P1103 (Year: 2022) Questioned Costs: None Identified Description: The Department of Human Services should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Food Distribution Cluster is comprised of the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP) and is intended to strengthen the nutrition safety net through the provisions of the U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. CSFP provides a package of USDA Foods to low-income elderly people at least 60 years of age. CSFP food packages are not intended to provide a complete diet but rather provide the nutrients that are typically lacking in the diets of the target population. TEFAP provides USDA Foods to low-income households for home consumption or for use in prepared meals at emergency feeding sites for low-income persons. USDA Foods associated with the Food Distribution Cluster programs are provided to the Department of Human Services (DHS) for allocation to eligible subrecipients. These subrecipients are responsible for the determination of individual eligibility and who receives benefits. Because the DHS subgrants donated foods to various entities, the DHS must perform certain monitoring activities related to these subrecipients. These monitoring activities include a review of individual eligibility determinations completed by subrecipients to ensure categorical and income eligibility requirements are met before distributing food items. Criteria: As a recipient of federal awards, the DHS is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that “All pass-through entities must… (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved…” Additionally, pursuant to Title 7 CFR Section 247.34(a), under the CSFP, “the State agency must establish a management review system to ensure that local agencies, subdistributing agencies, and other agencies conducting program activities meet program requirements and objectives. As part of the system, the State agency must perform an on-site review of all local agencies, and of all storage facilities utilized by local agencies, at least once every two years. As part of the on-site review, the State agency must evaluate all aspects of program administration, including certification procedures, nutrition education, civil rights compliance, food storage practices, inventory controls, and financial management systems. In addition to conducting on-site reviews, the State agency must evaluate program administration on an ongoing basis by reviewing financial reports, audit reports, food orders, inventory reports, and other relevant information.” Furthermore, pursuant to Title 7 CFR Section 251.10(e), under the TEFAP, “(1) Each State agency must monitor the operation of the program to ensure that it is being administered in accordance with Federal and State requirements… (2)… the State agency monitoring system must include: (i) An annual review of at least 25 percent of all eligible recipient agencies which have signed an agreement with the State agency… provided that each such agency must be reviewed no less frequently than once every four years; and (ii) An annual review of one-tenth or 20, whichever is fewer, of all eligible recipient agencies which receive TEFAP commodities and/or administrative funds pursuant to an agreement with another eligible recipient agency. Reviews must be conducted, to the maximum extent feasible, simultaneously with actual distribution of commodities and/or meal service, and eligibility determinations, if applicable. State agencies must develop a system for selecting eligible recipient agencies for review that ensures deficiencies in program administration are detected and resolved in an effective and efficient manner. (3) Each review must encompass, as applicable, eligibility determinations, food ordering procedures, storage and warehousing practices, inventory controls, approval of distribution sites, reporting and recordkeeping requirements, and civil rights. Condition: All subrecipients associated with the Food Distribution Cluster were selected for testing. Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: • Auditors reviewed documentation to determine if appropriate monitoring was conducted over CSFP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one of the two CSFP subrecipients tested. • Auditors also reviewed documentation to determine if appropriate monitoring was conducted over TEFAP subrecipients in accordance with the DHS internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for any of the seven TEFAP subrecipients tested and 13 of the required 20 TEFAP sub-distributing subrecipients. • As a result of not completing the required subrecipient monitoring reviews, the DHS also failed to review the subrecipients’ eligibility determinations for individual beneficiaries. Cause: Through discussion with management, high staff turnover, including the lack of a TEFAP and CSFP Coordinator, caused delays in conducting the required monitoring reviews. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal donated foods being distributed to ineligible individuals, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the DHS: • Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements and ensure individual eligibility determinations are being reviewed; • Develop an annual monitoring schedule for reviews of TEFAP and CSFP subrecipients to ensure compliance with monitoring of the required number of Eligible Recipient Agencies (ERAs); and • Maintain a tracking log that includes a listing of all TEFAP and CSFP subrecipients, date the monitoring review was performed, who completed the monitoring review, and if there were any deficiencies noted during the review. Views of Responsible Officials: The Georgia Department of Human Services (DHS) concurs with the finding.