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.
Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants Federal Award Identification Number and Year - N/A Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity Finding Type - Significant deficiency Repeat Finding - No Criteria - The College should have a subrecipient monitoring policy and defined procedures to follow when identifying and assessing subrecipients in accordance with 2 CFR section 200.332. Condition - The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Questioned Costs - N/A Context - There was one subrecipient for this grant. The College was required to find a subrecipient and selected a similar organization that they collaborate with on other projects. The selected subrecipient meets with the College monthly and provides and submit quarterly reimbursement forms and performance data. This is also the College's first subrecipient agreement. Cause and Effect - The College did not have a system or process in place to select a subrecipient using a risk analysis process. As a result, the subrecipient chosen may not have been eligible or at risk of providing timely or accurate performance and financial data. Recommendation - We recommend the College develop a subrecipient policy with defined procedures in alignment with Uniform Guidance in the efect they have subrecipients in the future for this and other grants. Views of Responsible Officals and Corrective Action Plan - The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management.
SUBRECIPIENT MONITORING Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Grant Number & Year: NA Federal Grantor Agency: U.S. Department of the Treasury Repeat Finding: No Questioned Costs: $750,000 likely Condition: The County lacked procedures to ensure that subrecipients documented their use of Federal awards appropriately. Criteria: Per 2 CFR § 200.332 (January 1, 2022), all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purpose, 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 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. Cause: There were not proper procedures in place for subrecipient monitoring. Potential Effect: Without adequate supporting documentation and monitoring procedures, there is an increased risk that Federal Awards could be used for unallowable costs. Recommendation: We recommend that the County improve procedures to monitor subrecipients, including reviewing detailed supporting documentation for expenses and following up with subrecipients to ensure that they correct errors noted. The County may also want to consider using only reimbursement basis grants, so the supporting documentation is received prior to payment to subrecipients. This would help prevent issues of obtaining documentation to support the payments. Views of Officials: The County is aware of the above finding and has adjusted our procedures related to disbursing federal funds to subrecipients. We have changed to a cost reimbursement basis for disbursing the federal funds to subrecipients. We currently receive supporting documentation prior to payment.
Finding Number: 2023-008 State/Educational Agency(s): Arkansas Department of Commerce – Arkansas Economic Development Commission Pass-Through Entity: Not Applicable ALN Number(s) and Program Title(s): 21.027 – COVID 19: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Federal Awarding Agency: U.S. Department of Treasury Federal Award Number(s): SLFRP3627 Federal Award Year(s): 2021 Compliance Requirement(s) Affected: Subrecipient Monitoring Type of Finding: Material Noncompliance and Material Weakness Repeat Finding: A similar issue was reported in prior-year finding 2022-018. Criteria: In accordance with 2 CFR § 200.332(a)(1), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward: i. Subrecipient name (which must match the name associated with its unique entity identifier). ii. Subrecipient's unique entity identifier. iii. Federal Award Identification Number (FAIN). iv. Federal award date. v. Subaward Period of Performance start and end date. vi. Subaward budget period start and end date. vii. Amount of federal funds obligated by this action by the pass-through entity to the subrecipient. viii. Total amount of federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation. ix. Total amount of the federal award committed to the subrecipient by the pass-through entity. x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA). xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity. xii. Assistance listings number (ALN) and title; the pass-through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement. xiii. Identification of whether the award is Research & Development. xiv. Indirect cost rate for the federal award. In addition, 2 CFR § 200.332(a)(4) requires an approved federally recognized indirect cost rate between the subrecipient and the federal awarding agency. 2 CFR § 200.332(b) states that pass-through entities must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Finally, 2 CFR § 200.332(d) states that pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward performance goals are achieved. Section 9(G) of the Arkansas Rule Connect (ARC) rules state that within 45 days after grant approval, the Internet Service Provider (ISP) should submit the project plans to a licensed Professional Engineer (PE) for a technical adequacy confirmation. Once received, the ISP should submit the PE approval stamp to the Arkansas State Broadband Office (ASBO). Condition and Context: ALA staff reviewed seven executed grant agreements, totaling $28,392,301, to determine if they met the Uniform Guidance criteria. The following deficiencies were noted: • The seven grant agreements did not include all required terms, specifically from the criteria noted above, ii, iii, iv, xi, xii, xiii, and xiv. • An indirect cost rate agreement could not be provided. • Discussion with management indicated that the ISPs were evaluated during the application process, but the results were not documented. Without proper documentation, ALA staff were unable to determine if the ISPs were assessed for risk as required by Uniform Guidance (2 CFR § 200.332(b)). • Discussion with management indicated that the pass-through entity did not have documentation indicating that a PE reviewed the technical adequacy of any of the seven projects ALA reviewed. Statistically Valid Sample: Not a statistically valid sample Questioned Costs: None Cause: The Agency did not ensure staff were trained and knowledgeable regarding Uniform Guidance requirements for subrecipients. Effect: Without a proper grant agreement, subrecipients may be unaware that their award is subject to federal compliance requirements. The Agency could award federal funds to a high risk entity and fail to adjust the methods of monitoring accordingly. Absent a review by a PE, the project may fail to comply with performance requirements. Recommendation: ALA staff recommend the Agency provide training to appropriate staff to ensure adherence to Uniform Guidance regarding subrecipient monitoring. Views of Responsible Officials and Planned Corrective Action: ASBO has developed a Notice of Subgrant Award Information Form providing required information to each subrecipient. We have already sent this form out for CPF grants as an amendment to the current grant award. This form will be part of the subawards that will be issued for the upcoming BEAD subgrants. We are currently developing this form for all SLFRF grants to be sent out as an amendment. It is currently being reviewed for changes. Our goal is to have this form out as an amendment to all SLFRF subgrantees by June 1, 2024. Anticipated Completion Date: June 1, 2024 Contact Person: Glen E. Howie Director Department of Commerce, Arkansas State Broadband Office 1 Commerce Way, Suite. 601 Little Rock, AR 72202 (501) 682-1123 Glen.Howie@ArkansasEDC.gov
Finding 2023-001: Subrecipient Monitoring (Material Weakness) Federal Program: U.S Department of the Treasury: ALN 21.027 Criteria or Specific Requirement: As stated in 2 CFR 200.332, the requirements for pass-through entities include a) ensuring that every subaward is clearly identified to the subrecipient as a subaward; b) evaluating each subrecipient's risk of noncompliance; c) monitoring the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes; d) performing certain monitoring activities to ensure proper accountability and compliance with program requirements and achievement of performance goals depending upon the pass-through entity's assessment of risk posed by the subrecipient; e) verifying that every subrecipient is audited as required by Subpart F of the Uniform Guidance; f) determining whether the results of the subrecipient's audits, on-site reviews, or other monitoring activities indicate conditions that necessitate adjustments to the pass-through entity's own records; and g) taking enforcement action against noncompliant subrecipients, if necessary. Condition: While AHCMC has a process in place for evaluating risk, it does not have a formal documented subrecipient policy that encompasses all the requirements of the Uniform Guidance. AHCMC's subrecipient agreements did not clearly identify the Assistance Listing Number (ALN) related to the subaward. AHCMC did not monitor the activities of the subrecipients in accordance with the Uniform Guidance. Cause: AHCMC did not fully adhere to the Uniform Guidance related to requirements for pass-through entities. Effect or Potential Effect: AHCMC's subrecipients may not have been aware that they had received Federal pass-through subawards since the agreements did not clearly indicate the ALN of the subaward. AHCMC did not perform the appropriate level of monitoring to ensure subrecipients expended funds in accordance with the provisions and terms of the subaward and the Uniform Guidance. Questioned Costs: None noted. Context: AHCMC did not clearly inform subrecipients that they received Federal pass-through subawards by including the ALN in the subaward agreements and AHCMC did not perform subrecipient monitoring in accordance with the Uniform Guidance. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: AHCMC should ensure that every subaward is clearly identified to the subrecipient as a Federal pass-through subaward and that the agreement includes the ALN. Based on the risk assessment for each subrecipient, we recommend that AHCMC assign a risk level to each subrecipient and then determine the monitoring tools to apply based on these risk levels, such as requiring subrecipients to submit financial or programmatic reports to demonstrate and ensure subrecipients are expending funds appropriately. In addition, AHCMC should ensure that subrecipients obtained a single audit if required by Subpart F of the Uniform Guidance.
Finding Reference 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agency: P.R. Department of Housing Program: Community Development Block Grant/State’s Program and Non-Entitlement Grants in Hawaii (Assistance Listing No. 14.228) Compliance Requirement: Reporting – Performance Reporting (L) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Statement of Condition In our reporting test, we found that the Municipality did not submit the reports corresponding to audit year in the required time frame: • The first quarter (July-September 2022) and the second quarter (October-December 2022) were submitted on March 3, 2023. • The third quarter (January-March 2023) was submitted to May 24, 2023. • The fourth quarter (April-June 2023) was submitted to August 31, 2023. Criteria Based on the CDBG agreements, the Municipality must submit to the Department of Housing reports on records, collections, and disbursements of Program Income on an annual and quarterly basis. Including the progress of the projects developed with the CDBG program. In addition, the Municipality will submit all the reports required by the Agency. Failure to comply with this provision will be just cause for the Department to stop the fund requisition process. § 200.332 Requirements for pass-through entities. (1) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (2) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, in OCAM Memorandum Circular 2002-15 of July 17, 2002, it is established that quarterly reports must be submitted within the following 40 days after the expiration date of the quarter. Cause of Condition The personal in charge of the program did not comply with the deadlines for the quarterly reports. Additionally, the program does not have adequate monitoring of the activity and the reports, which were delivered late. Effect of Condition The program is not in compliance with the Reporting Requirements. Recommendation We recommend that the Municipality maintain constant monitoring and updating to achieve better control of the program. The reports must be presented as established in the agreement and guidelines of the Department of Housing. This will ensure compliance with reporting requirements under the Community Development Block Grants/State’s Program and Non-entitlement Grant in Hawaii agreement. Questioned Cost None Prior Year Finding No Views of Responsible Officials and Planned Corrective Action The Program Director is aware about the compliance requirement. We gave instructions to the Program Director to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Implementation Date: March 21, 2024 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director
Finding Reference 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agency: P.R. Department of Housing Program: Community Development Block Grant/State’s Program and Non-Entitlement Grants in Hawaii (Assistance Listing No. 14.228) Compliance Requirement: Reporting – Performance Reporting (L) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Statement of Condition In our reporting test, we found that the Municipality did not submit the reports corresponding to audit year in the required time frame: • The first quarter (July-September 2022) and the second quarter (October-December 2022) were submitted on March 3, 2023. • The third quarter (January-March 2023) was submitted to May 24, 2023. • The fourth quarter (April-June 2023) was submitted to August 31, 2023. Criteria Based on the CDBG agreements, the Municipality must submit to the Department of Housing reports on records, collections, and disbursements of Program Income on an annual and quarterly basis. Including the progress of the projects developed with the CDBG program. In addition, the Municipality will submit all the reports required by the Agency. Failure to comply with this provision will be just cause for the Department to stop the fund requisition process. § 200.332 Requirements for pass-through entities. (1) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (2) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, in OCAM Memorandum Circular 2002-15 of July 17, 2002, it is established that quarterly reports must be submitted within the following 40 days after the expiration date of the quarter. Cause of Condition The personal in charge of the program did not comply with the deadlines for the quarterly reports. Additionally, the program does not have adequate monitoring of the activity and the reports, which were delivered late. Effect of Condition The program is not in compliance with the Reporting Requirements. Recommendation We recommend that the Municipality maintain constant monitoring and updating to achieve better control of the program. The reports must be presented as established in the agreement and guidelines of the Department of Housing. This will ensure compliance with reporting requirements under the Community Development Block Grants/State’s Program and Non-entitlement Grant in Hawaii agreement. Questioned Cost None Prior Year Finding No Views of Responsible Officials and Planned Corrective Action The Program Director is aware about the compliance requirement. We gave instructions to the Program Director to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Implementation Date: March 21, 2024 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director
Finding Reference 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agency: P.R. Department of Housing Program: Community Development Block Grant/State’s Program and Non-Entitlement Grants in Hawaii (Assistance Listing No. 14.228) Compliance Requirement: Reporting – Performance Reporting (L) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Statement of Condition In our reporting test, we found that the Municipality did not submit the reports corresponding to audit year in the required time frame: • The first quarter (July-September 2022) and the second quarter (October-December 2022) were submitted on March 3, 2023. • The third quarter (January-March 2023) was submitted to May 24, 2023. • The fourth quarter (April-June 2023) was submitted to August 31, 2023. Criteria Based on the CDBG agreements, the Municipality must submit to the Department of Housing reports on records, collections, and disbursements of Program Income on an annual and quarterly basis. Including the progress of the projects developed with the CDBG program. In addition, the Municipality will submit all the reports required by the Agency. Failure to comply with this provision will be just cause for the Department to stop the fund requisition process. § 200.332 Requirements for pass-through entities. (1) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (2) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Additionally, in OCAM Memorandum Circular 2002-15 of July 17, 2002, it is established that quarterly reports must be submitted within the following 40 days after the expiration date of the quarter. Cause of Condition The personal in charge of the program did not comply with the deadlines for the quarterly reports. Additionally, the program does not have adequate monitoring of the activity and the reports, which were delivered late. Effect of Condition The program is not in compliance with the Reporting Requirements. Recommendation We recommend that the Municipality maintain constant monitoring and updating to achieve better control of the program. The reports must be presented as established in the agreement and guidelines of the Department of Housing. This will ensure compliance with reporting requirements under the Community Development Block Grants/State’s Program and Non-entitlement Grant in Hawaii agreement. Questioned Cost None Prior Year Finding No Views of Responsible Officials and Planned Corrective Action The Program Director is aware about the compliance requirement. We gave instructions to the Program Director to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Implementation Date: March 21, 2024 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director
Criteria: Per 2 CFR § 200.332(a)(1), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include federal award identifying information such as the total amount of federal funds committed to the subrecipient by the pass-through entity, name of the federal awarding agency, and assistance listing number and title. Condition: Communication with the subrecipient includes the grant name and total funds committed to the subrecipient, but it does not disclose the portion that is federal funds, the federal awarding agency, or the assistance listing number and title. Cause: Grant agreements with the subrecipient have not historically included this information and templates were used from prior years to prepare the latest agreements. Effect: The subrecipient was not aware that their award included federal funds, and so did not include it on their Schedule of Expenditures of Federal Awards. Management's Response: The identified deficiency relates to the Safe Routes to School (SRTS) funds (OBAG 2 funds) passed through via agreement with the San Mateo County Office of Education (SMCOE). As noted by the auditor, the agreement describes the funding source with the same language previously used in prior grant agreements. Specifically, on page 26, the existing grant agreement states: “C/CAG and SMCOE have a joint interest in ensuring that schools and community agencies effectively implement programs that enable them to use the Federal Surface Transportation Program and Congestion Mitigation & Air Quality Improvement (STP/CMAQ) Program funds productively on behalf of students and the community.” To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit requirements and 2 CFR § 200.332 Requirements for pass-through entities.